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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 enforcement