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Lauren   April 13th, 2021   Uncategorized No Comments

6. Did the person involved enter into a statute of limitations when requested by OFAC (particularly in cases where the obvious offences were not immediately reported or discovered to OFAC in particularly complex cases and in cases where the person concerned requested and obtained additional time to respond to a request for information from OFAC)? If this is the case, the conclusion of a toll agreement is considered a mitigating factor. Two 2018 enforcement actions (Societe Generale and Ericsson Inc./Ericsson AB) dealt with allegations of violations of Sudanese sanctions regulations adopted since 2012 or earlier, and a third enforcement measure (JPMorgan) related to pre-2015 conduct. The general statute of limitations for violations of U.S. sanctions is five years from the date of the violation. However, enforcement objectives regularly include toll agreements with OFAC to ensure full borrowing for cooperation, which extends the applicable limitation period (in some cases, significantly). ofAC took into account several mitigating factors in determining the amount of compensation, including (i) OFAC did not commit any violations of the bank in the five years prior to the earliest date of the disputed transactions; (ii) the Bank has cooperated fully in the investigation of the alleged offences, including the conclusion of a statute of limitations and the agreement to extend the agreement; (iii) the Bank presented significant investigative evidence concerning a foreign financial institution that hosted an account involved in the settlement of transactions; and (iv) the Bank has taken several corrective measures in response to alleged violations, such as exiting the Sudanese market in 2014, hiring new executives and implementing improvements to its compliance program. 1. Billing process. Settlement interviews may be initiated by OFAC, the person concerned or the authorized representative of the person concerned. Settlements are generally negotiated in accordance with the principles set out in these guidelines with respect to appropriate penalty amounts. OFAC may pre-condition the entry or continuation of transaction negotiations on the implementation of a toll agreement with respect to the limitation period.

The OFAC enforcement guidelines state that the “finding of a toll agreement” of an implementation objective is considered a “basis for mitigating the enforcement response or reduction in the amount of the penalty,” but states that “refusal to enter into a toll agreement is not an aggravating factor in the assessment … Cooperation or any other way.┬áThe fact that OFAC`s enforcement objectives regularly lead to toll agreements suggests that companies (and sanctions practitioners) continue to view cooperation with OFAC as an interesting proposal (probably, at least in part, because of the relatively transparent way in which these cooperative factors lead to sanctions). While OFAC is quite liberal when it comes to granting extensions, there is often a considerable delay between the occurrence of a clear violation and the period in which OFAC is able to investigate the matter. Therefore, the granting of extensions by OFAC may lead to situations where the overt offences are outside of the five-year period of OFAC.

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