On March 27, 2019, the Office of Foreign Assets Control (OFAC)
announced a settlement agreement with US-based
Stanley Black & Decker, Inc., (Stanley Black & Decker) and
its foreign subsidiary, Jiangsu Guoqiang Tools Co., Ltd. (GQ), in
which Stanley Black & Decker agreed to pay $1,869,144 on behalf
of GQ for the subsidiary's unauthorized export of various tools
and related parts to Iran. OFAC published a public version of the
settlement agreement.
The enforcement action and ensuing settlement agreement are
particularly notable for two reasons. First, on the settlement
agreement, OFAC has provided significant guidance on what it
appears to consider to be best practices in maintaining a
risk-based sanctions compliance program.1 Although it
was unusual for OFAC to communicate that guidance in a settlement
agreement, we expect that OFAC's compliance and enforcement
guidance will increasingly take that form. Second, the action hints
at the trends that OFAC enforcement
