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Reporting a Violation of U.S. Economic Sanctions Can Potentially Qualify for a SEC Whistleblower Award

Violating U.S. economic sanctions can also violate disclosure duties under federal securities laws.  For example, Section 219 of the Iran Threat Reduction and Syria Human Rights Act of 2012 requires SEC-registered issuers to disclose all Iran-related activities covered by sanctions restrictions. The SEC’s Office of Global Security Risk (OSGC) monitors issuers’ disclosures related to business activities involving US sanctioned counties.
Recent Office of Foreign Assets Control penalties for sanctions violations have been substantial.  In March 2017, Zhongxing Telecommunications Equipment Corporation paid $100,871,266 in a settlement agreement for 251 apparent violations of the Iranian Transactions and Sanctions Regulations.  ZTE used third-party companies to surreptitiously supply Iran with a substantial volume of U.S.-origin goods, including controlled goods appearing on the Commerce Control List.

Guidance on OFAC’s Enforcement and Compliance Policies

Qualifying for an SEC Whistleblower Award

Experienced, Top-Rated SEC Whistleblower Lawyers

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