Monthly Archives: March 2017

March 31, 2017

Recent U.S. Government Actions Highlight the Inherent Risk to U.S. and Foreign Companies Doing Business in Lebanon

by Steven Pelak and Jeremy Paner

Last week, the Acting U.S. Attorney for the Southern District of New York announced the settlement of a civil fraud suit against American University of Beirut (AUB) and payment of a $700,000 penalty for alleged False Claims Act (FCA) violations arising from OFAC sanctions violations.  The alleged violations arose from false certifications of economic sanctions compliance made by AUB to the U.S. Agency for International Development (USAID) in connection with U.S. Government grants.  According to the settlement, AUB provided USAID annual certifications that it did not provide “material support or resources” to designated entities or individuals on the Specially Designated Nationals (SDN) List of the Treasury Department’s Office of Foreign Assets Control (OFAC).

As part of the settlement, AUB admitted to a series of sanctions violations involving three separate Hizballah designated entities.  AUB acknowledged that it provided journalism training workshops attended by representatives of two designated Hizballah media entities, and separately promoted a designated Hizballah construction company through its inclusion on a publicly accessible online database.  AUB agreed to pay $700,000 and strengthen its compliance program to resolve the civil action. Continue reading