Episode 63 -- The Epsilon Case and Third Party Sanctions Risks
The Department of Treasury's Office of Foreign Asset Control (OFAC) recently settled a long-active enforcement action with Epsilon relating to alleged violations of the Iran Sanctions Program. After a mixed decision from the US Court of Appeals for the District of Columbia Circuit, OFAC negotiated a $1.5 settlement for 39 violations of the Iran Sanctions Program. Along the way, however, OFAC secured favorable rulings affirming application of its broad prohibition against third-party conduct where a company knows or has "reason to know" that a shipment intended to a third party may be shipped to a prohibited party.
In this episode, Michael Volkov discusses the Epsilon case and the implications for third party risks in sanctions cases.
