Framework for OFAC Compliance Commitments

The past year has witnessed a massive increase in sanctions-related enforcement activity and has indeed caused a stir in the global sanctions landscape. Under the new administration, the US re-imposed all nuclear-related sanctions on Iran, culminating in the largest ever single set of sanctions designations to date.

With the heightened global regulatory environment and the aggressive stance of enforcement agencies, it has been made rather clear that sanctions laws can no longer be ignored. Moreover, in an attempt to bring clarity to compliance expectations of the sanctions regime in the US, on May 02, 2019, the Office of Foreign Assets Control (OFAC) published the Framework for OFAC Compliance Commitments (Framework). The Framework sets out OFAC’s key considerations for evaluating the efficacy of a sanctions compliance programme (SCP) and in turn determining whether mitigation of civil monetary penalties ought to be granted.
Continue Reading

As anticipated in our last blog on this subject , solar cells continue to be at the heart of to-and-fro trade remedy measures being undertaken by various countries. The Government of India has fired the most recent salvo by notifying the imposition of safeguard duty on solar cells through the Department of Revenue, Ministry of Finance.

The termination of the anti-dumping investigation by the Directorate General of Anti-dumping and Allied Duties (DGAD) may have allowed a temporary sigh of relief to those rooting for exports. But that has been largely offset because of the safeguard duty investigation by the Directorate General of Safeguards (DGS).

The safeguard duty investigation was initiated based on a petition filed by the Indian Solar Manufacturers Association (ISMA) with the DGS requesting imposition of a safeguard duty on imported solar cells from China, Malaysia, Singapore and Taiwan.


Continue Reading