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OFAC Raises the Compliance Bar: Takeaways from the Stanley Black & Decker Settlement
On March 27, the Office of Foreign Assets Control (“OFAC”) announced a $1.869 million settlement with Stanley Black & Decker, Inc. (“SB&D”) and its Chinese subsidiary, Jiangsu Guoqiang Tools Co., Ltd. (“GQ,” and collectively with SB&D, the “Company”), to resolve 23 apparent violations of the Iranian Transactions and Sanctions Regulations (“ITSR”). In addition to a civil penalty, the settlement imposes extensive sanctions compliance commitments on the Company, backed by a five-year annual certification requirement.