Clifford Chance
Caveat Emptor – OFAC Fines Creditor for Buying SDN's Troubled Debt
19 August 2019
On August 16, 2019, OFAC announced a settlement with Atradius Trade Credit Insurance, Inc. ("ATCI"), a US subsidiary of Netherlands-based Altradius N.V.1 ATCI paid $345,316 to settle potential civil liability for two apparent violations of the Foreign Narcotics Kingpin Sanctions Regulations (31 C.F.R. Part 598) for receiving payments from the liquidation of a Panama-based shopping mall on the List of Specially Designated Nationals and Blocked Persons. OFAC determined that ATCI did not voluntarily disclose the apparent violations, but that they were non-egregious.
