June 30, 2019 · Matthew Goldstein
HEXDI Integrates Black and Decker Settlement Agreement
Pursuant to the terms of a March 2019 Settlement Agreement entered into by the Department of Treasury Office of Financial Assets Control (“OFAC”) and Stanley Black & Decker, Inc. (“Black & Decker”), OFAC and Black & Decker agreed to settle Black & Decker’s potential civil liability for apparent violations of the Iranian Transactions and Sanctions Regulations committed by its Chinese-based subsidiary Jiangsu Guoqiang Tools Co. Ltd. [F/N 1]
As part of the Consent Agreement, Black & Decker agreed to institute a variety of compliance measures and pay a civil penalty of $1,869,144 dollars.
Black & Decker also agreed to maintain sanctions compliance measures designed to minimize the risk of similar conduct in the future. These measures include a method to identify, analyze, and address the particular risks faced by Black & Decker.
HEXDI has integrated 24 additional government standards reflected in the Black & Decker Settlement Agreement, which are now included in HEXDI modules 1 through 12.
[F/N 1] See Office of Foreign Assets Control, Black & Decker Settlement Agreement (March 2019), available at www.treasury.gov/resource-center/sanctions/CivPen/Documents/20190327_decker_settlement.pdf
This case is also indexed in HEXDI's Cost of Non-Compliance dataset, alongside other public export-control and sanctions enforcement actions.
The above is not intended as an exhaustive list of restrictions that may apply to a particular transaction nor advice for a specific transaction because the specifics of an individual case may implicate application of other U.S. laws as well as foreign laws that carry added or different requirements. In addition, U.S. export control and sanctions laws are frequently subject to change. Such changes can affect the continued validity of the information above.