OFAC Agreement Highlights Importance of Knowing 4th Parties

Eyelashes expose weaknesses in 4th party and supplier due diligence.

Today the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced a settlement of $996,080 with e.l.f. Cosmetics, Inc. (“ELF”) of Oakland, California. ELF has agreed to settle its potential civil liability for 156 apparent violations of the North Korea Sanctions Regulations, 31 C.F.R. part 510 (NKSR).

The apparent violations involved the importation of false eyelash kits from two suppliers located in the People’s Republic of China that contained materials sourced by these suppliers from the Democratic People’s Republic of Korea.

The Office of Foreign Assets Control stated: “This enforcement action highlights the risks for companies that do not conduct full-spectrum supply chain due diligence when sourcing products from overseas, particularly in a region in which the DPRK, as well as other comprehensively sanctioned countries or regions, is known to export goods. OFAC encourages companies to develop, implement, and maintain a risk-based approach to sanctions compliance and to implement processes and procedures to identify and mitigate areas of risks.”