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ARTICLE · 22 APRIL 2015

PayPal, Schlumberger Holdings Enforcement Actions Highlight Need For Effective Implementation Of Compliance Programs

Jones Day
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By the time PayPal had implemented these changes, it had processed hundreds of transactions involving sanctioned countries or parties.

United StatesInternational Law
Laura Fraedrich
Laura Fraedrich
Michael Gurdak
Michael Gurdak
Fahad Habib
Fahad Habib
Chad Dorr
Chad Dorr
Chase Kaniecki
Chase Kaniecki
D. Grayson Yeargin
D. Grayson Yeargin
Paul Hines
Paul Hines
Lindsey Nelson
Lindsey Nelson
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Recent enforcement actions against PayPal, Inc. ("PayPal") and Schlumberger Oilfield Holdings Ltd. ("Schlumberger Holdings") serve as a reminder to all companies subject to U.S. economic sanctions that no matter how robust corporate compliance policies may appear on paper, an ineffectively implemented compliance policy will not mitigate or insulate companies from substantial penalties.

Paypal

On March 25, 2015, the U.S. Department of the Treasury's Office of Foreign Assets Control ("OFAC") announced that online financial services provider PayPal had entered into an agreement to settle allegations that it had committed numerous violations of U.S. sanctions regulations. Under the terms of the settlement agreement, PayPal will remit $7,658,300 to resolve potential civil liability arising from 486 transactions it processed in apparent violation of OFAC sanctions programs targeting Cuba, Iran, Sudan, the proliferation of weapons of mass destruction, and global

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