Examining the 3M Sanctions Settlement
GovCon & Trade
NOVEMBER 13, 2023
In an article for Law360, I examined the recent settlement between the U.S. Department of the Treasury’s Office of Foreign Assets Control and the 3M Company for nearly $10 million to resolve apparent violations of U.S. sanctions on Iran. While not the largest settlement this year, I pointed out that the 3M settlement is important for several reasons, including: “as to the complexity of U.S. sanctions; as to the duration of OFAC enforcement actions; and as to the benefits and potential drawbacks
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