Overview
On September 26, 2017, the US Office of Foreign Assets Control (OFAC) published information about a civil enforcement action against Richemont North America, d.b.a. Cartier, headquartered in New York. Richemont agreed to settle charges and pay approximately $334,800 for allegedly selling jewelry to a Specially Designated National and Blocked Person designated under the Foreign Narcotics Kingpin Sanctions Regulations located in Hong Kong. The matter was not voluntarily disclosed. OFAC determined that the circumstances were not egregious, but that a monetary penalty was warranted based on the circumstances. In the final paragraph, OFAC seemed to provide a warning about the risks for US companies with retail operations that engage in international transactions, particularly those that ship their products directly to customers outside the United States. In this regard, OFAC recommended that companies adopt a risk-based compliance program to identify and mitigate potential sanctions liabilities, identifying factors for consideration as part of such a program.
