Clifford Chance

OFAC Sends Message Regarding Post Acquisition Compliance Integration and Risk Management

October 1, 2020

On September 24, 2020, OFAC announced a settlement with California-based Keysight Technologies Inc. with respect to apparent violations of the Iranian Transactions and Sanctions Regulations committed by its then Finland-based subsidiary, Anite Finland OY, shortly after Anite had been acquired by Keysight. The case carries the lesson that acquiring companies in the face of known OFAC risk in their targets, should take affirmative steps post-acquisition to ensure and to verify that those risks are properly managed. OFAC determined that Keysight voluntarily disclosed the apparent violations, that they were egregious, and assessed a base penalty of $1,051,460. OFAC then reduced the final penalty to $473,157 based on a number of mitigating factors including Keysight's cooperation with OFAC, remedial measures and compliance enhancements.

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