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February 18, 2016

OFAC Issues FOV to Johnson & Johnson Subsidiary; Reminds U.S. Companies to Properly Train Staff

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) recently issued a Finding of Violation[1] to Johnson & Johnson Middle East Inc. (JJME), a wholly-owned U.S. subsidiary of Johnson & Johnson, for facilitating the export of consumer hygiene goods to Sudan in violation of the Sudanese Sanctions Regulations.[2]

According to OFAC, between roughly March 23, 2010 and October 20, 2010, JJME’s General Manager for Emerging Markets, Middle East, and North Africa coordinated and supervised five shipments from Johnson & Johnson (Egypt) S.A.E. to Khartoum, Sudan. The total value of the shipments was approximately $227,818. While it appeared that JJME had a compliance program in place, it did not include any training for this General Manager on compliance with OFAC regulations, even though he was responsible for sales involving the Middle East and North Africa, including Sudan. OFAC noted that the enforcement action “highlights the need for U.S. companies…to ensure that their employees are properly trained on OFAC regulations.”

[1] OFAC may issue a Finding of Violation when it determines that a violation has occurred and that an administrative response is warranted but, based on an analysis of the General Factors outlined in Section III of the Economic Sanctions Enforcement Guidelines, concludes that a civil monetary penalty is not the most appropriate enforcement response. See 31 CFR part 501, app. A.
[2] See 31 CFR part 538.