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ARTICLE · 14 JULY 2020

Amazon Settles OFAC Sanctions Violations

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Amazon settled OFAC charges for violating multiple sanctions programs by providing "goods and services to persons sanctioned by OFAC."

United StatesInternational Law
James Treanor
James Treanor
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Amazon settled OFAC charges for violating multiple sanctions programs by providing "goods and services to persons sanctioned by OFAC." The settlement also included failures to report hundreds of transactions subject to a General License related to winding down operations involving the Crimea region of Ukraine.

OFAC alleged that, between 2011 and 2018, Amazon conducted business with persons (i) located in Crimea, Iran and Syria, (ii) in embassies and missions of sanctioned countries, and (iii) listed on the Specially Designated Nationals and Blocked Persons List (the "SDN List") in violation of numerous prohibited sanctions regulations. OFAC stated that these violations took place primarily because Amazon's screening processes failed to (i) comprehensively analyze transaction and customer data relevant to OFAC sanctions compliance, (ii) detect the specific names or common alternative spellings of sanctions jurisdictions or (iii) flag the properly spelled names and

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