Enforcement Release - Essentra FZE

Date issued: Jul. 16 2020

You've hit a wall. Sign in if you have an account, learn more about TURBOFAC and subscription options, or purchase access to the text of the document on this page, the native .pdf file, and the associated TURBOFAC original commentary.
TURBOFAC is a module of the compliance platform OverRuled. To learn more about OverRuled, visit www.overruled.com.

TURBOFAC Commentary (955 words)

Consolidated comment on the Essentra FZE Case

1) This comment addresses the following documents in the Research System:

* Civil Enforcement Information - Essentra FZE
* Settlement Agreement (OFAC) - Essentra FZE
* Deferred Prosecution Agreement - Essentra FZE (“the DPA”)

See DOJ Press Release at https://www.justice.gov/opa/pr/essentra-fze-admits-north-korean-sanctions-and-fraud-violations-agrees-pay-fine.

2) The Essentra FZE case is the first enforcement action since 2014 to be (i) against a non-bank entity and (ii) result in concurrent OFAC-administered civil penalty and DOJ-issued Deferred Prosecution Agreement. The reason for this is, evidently, the willful and evasive nature of the conduct underlying the violations, as described in the associated documents.

3) BASES FOR LIABILITY

While the fact pattern is relatively rare, the bases for liability are...