Clifford Chance

Contract clauses are not a safe harbor for OFAC compliance

September 18, 2020

OFAC's recent settlement with Comtech Telecommunications Corp. and Comtech EF Data Corp transmits important compliance lessons to companies.

On September 17, 2020, OFAC announced a settlement with New York-based Comtech Telecommunications Corp. and its wholly owned subsidiary based in Arizona, Comtech EF Data Corp. The settlement related to the alleged "indirect export" of warrantied satellite equipment and services and training to the Sudan Civil Aviation Authority, which was prohibited by OFAC's Sudanese Sanctions Regulations, 31 C.F.R. part 538 at the time of the transactions in 2014/2015.

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