16
Agreement, Honeywell agreed to pay a civil penalty of $13 million, $5 million of which will be suspended so that
Honeywell can direct these funds to strengthen its compliance program. In addition, Honeywell agreed to
engage an external Special Compliance Officer to oversee the Consent Agreement. In determining the
settlement amount, the State Department noted that Honeywell voluntarily disclosed the alleged violations.
ABU DHABI
AUSTIN
BEIJING
BRUSSELS
DALLAS
DUBAI
FRANKFURT
HONG KONG
HOUSTON
LONDON
MENLO PARK
MILAN
MUNICH
NEW YORK
PARIS
RIYADH*
ROME
SAN FRANCISCO
SÃO PAULO
SHANGHAI
SINGAPORE
TOKYO
TORONTO
WASHINGTON, DC
Shearman & Sterling has long advised financial institutions and commercial
businesses on the most complex sanctions issues. If you have any
questions, please feel free to contact one of our partners or counsel.
Authors & Contributors
Philip Urofsky
Danforth Newcomb
Stephen Fishbein
Brian G. Burke
Christopher L. LaVigne
Barnabas Reynolds
Mark D. Lanpher
Paula Howell Anderson
Adam B. Schwartz
Katherine J. Stoller
Associate Contributors
Jacob Fields
Cole Pritchett
Related Services
Sanctions, Litigation, Anti-Corruption & Foreign Corrupt Practices Act (FCPA)
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