3M OFAC Enforcement Action

Compliance into the Weeds

The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on sanctions compliance? Look no further than Compliance into the Weeds! In this episode, Tom and Matt consider the recent OFAC enforcement action involving 3M.

3 3M, found itself in hot water after violating Iran sanctions, leading to a hefty fine of $9,618,477 from the Treasury Department and OFAC. This violation, involving a subsidiary selling goods to a German reseller who then sold them directly to Iran, including to a sanctioned entity.

Tom points out the significant failures in controls and monitoring within the company that led to the violation. He emphasizes the importance of end user statements and monitoring in compliance functions to prevent such violations. On the other hand, Matt acknowledges that while 3M made an effort to comply with the Iran nuclear deal, changes in the arrangement that were not properly communicated or approved led to a violation of the sanctions agreement. He also underscores the importance of monitoring and obtaining end user statements to ensure compliance with export control laws.

Join Tom Fox and Matt Kelly as they delve deeper into this topic in the latest episode of the Compliance into the Weeds podcast.

Key Highlights

· Sanctions Compliance and Ongoing Monitoring

· Challenges and Consequences of Sanctions Compliance

· Sanctions Settlement for Selling Goods to Iran

· Anticipated Impact of Recent Events on 3M

Resources

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Matt on Radical Compliance

Tom

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