On 25 April 2022, The United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced a settlement with Australian company Toll Holdings Limited (“Toll”) of roughly US$6.1m for apparent violations of several US sanctions regimes. Toll’s story provides a useful reminder to non-US businesses of the importance of compliance with US sanctions in the global marketplace and insight into OFAC’s thinking when assessing penalties for violations.
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