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False Eyelashes Catch Our Attention in More Ways Than One

Written by: John Parkerson, Esq.

Note the interesting recent “reminder” about the Treasury Department’s Office of Foreign Assets Control (OFAC) enforcement of laws prohibiting doing business with certain countries, entities and persons: https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pages/20190131.aspx . Be careful about what you import, and ensure that your company has an internal program to prevent OFAC regulations violations. In this case, a U.S. cosmetics company imported from China false eyelashes kits that contained materials originating from North Korea. The relatively large size of the fine (almost $1 million) that OFAC imposed on the offending U.S. company was in part because the company’s “compliance program was either non-existent or inadequate.” The fine would have been even larger had the company not self-disclosed its violations.

HBS’ international business practice group has in-depth expertise in import/export as well as anti-corruption laws applicable to international business transactions. It can assist in tailoring compliance programs (including checklists, training programs, contract clauses, and website content) that help prevent or mitigate your company’s potential liability in this area.