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ARTICLE · 10 MAY 2021

OFAC Enforcement Actions Highlight Risks To Software Providers & MSBs

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On April 29, 2021, the US Department of the Treasury's Office of Foreign Assets Control (OFAC) announced two settlements of potential civil liability with two companies...

United StatesInternational Law
Michael Dawson
Michael Dawson
Ronald Meltzer
Ronald Meltzer
David Horn
David Horn
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Zachary Goldman
Semira Nikou
Semira Nikou
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Alina Lindblom
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On April 29, 2021, the US Department of the Treasury's Office of Foreign Assets Control (OFAC) announced two settlements of potential civil liability with two companies over their apparent violations of its regulations. The companies, MoneyGram Payment Systems, Inc. (MoneyGram) and SAP SE (SAP), operate in sectors of the economy—payments and software—that present unique sanctions risks and compliance challenges.

The two settlements highlight many of those risks, such as the reliance on third-party resellers, the integration of newly acquired companies, and contracting with the US government. They are part of a trend of increased OFAC enforcement1 and OFAC's communication of its compliance expectations through civil enforcement actions (which reinforce the guidance OFAC provided in its 2019 Framework for OFAC Compliance Commitments (Framework)). The SAP case is also notable because it is the first instance in which a company made a voluntary self-disclosure

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