News & Analysis as of

Office of Foreign Assets Control (OFAC) Corporate Culture

Akin Gump Strauss Hauer & Feld LLP

Federal Agency Settlements with Wells Fargo Illustrate Sanctions Risks Involving IT Systems

Key Points - On March 30, 2023, OFAC announced a settlement agreement with Wells Fargo for 124 apparent violations of three different sanctions programs (Iran, Syria and Sudan), all related to a legacy Wachovia Bank...more

The Volkov Law Group

Wells Fargo Fumbles Sanctions Compliance Demonstrating An Absence of Culture of Compliance (Part II of II)

The Volkov Law Group on

Not that I am a glutton for punishment, but I always find enforcement actions to supply a number of valuable lessons learned. There are always instructive nuggets of information, opportunities missed, and root causes that...more

NAVEX

A Review of Risk & Compliance in 2022

NAVEX on

As 2022 comes to a close, now is an ideal time to reflect on the developments and challenges this year held for the risk and compliance profession – and there was no shortage of either. The complexity of maintaining...more

The Volkov Law Group

Troubling Trends: The CCO’s Authority, Independence and Access to Resources (Part II of III)

The Volkov Law Group on

While my first posting highlighted the positive developments in the CCO’s role and professional development, the next two postings present troubling concerns....more

The Volkov Law Group

Ethics and Compliance Trends and Predictions for 2020

The Volkov Law Group on

2019 was a big year for ethics and compliance.  In fact, it is easy to argue that since the adoption of the compliance provisions in the US Sentencing Guidelines in 1991, compliance had its biggest year....more

Thomas Fox - Compliance Evangelist

Antitrust Compliance Programs: Part 2 – Elements of an Effective Compliance Program (Elements 1-4)

As the third in a triumvirate of releases on compliance programs, the Department of Justice (DOJ) Antitrust Division, in July the released its Evaluation of Corporate Compliance Programs in Criminal Antitrust Investigations...more

The Volkov Law Group

Watching the River Flow: The Evolution and Future of Compliance (Part I of III)

The Volkov Law Group on

Bob Dylan, Watch the River FlowI have to admit it – I still love to listen to Bob Dylan.  With age, his lyrics resonate more and more.  HERE is a nice version of Watch the River Flow in case you want to listen while reading...more

Hogan Lovells

OFAC outlines expectations for global sanctions compliance

Hogan Lovells on

On 2 May 2019 the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) issued "A Framework for OFAC Compliance Commitments" (the framework), which outlines five components OFAC considers to be essential...more

Sheppard Mullin Richter & Hampton LLP

Feds Focus on Individuals in Evaluating Corporate Compliance Programs

Earlier this month, the U.S. Department of Justice (“DOJ”) and the U.S. Department of the Treasury’s Office of Foreign Asset Controls (“OFAC”) both issued guidance regarding their expectations for corporate compliance...more

Dorsey & Whitney LLP

OFAC Issues Sanctions Guidance and the Concept of Culture Gains Traction (With Chinese Translation)

Dorsey & Whitney LLP on

On May 2, 2019, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”)—the U.S. agency tasked with administering and enforcing the U.S.’s economic and trade sanctions programs—published A Framework for...more

Jones Day

Understanding the DOJ’s Updated Guidance on Corporate Compliance Programs

Jones Day on

The Situation: On April 30, 2019, the U.S. Department of Justice ("DOJ") released an updated version of its guidance document, "Evaluation of Corporate Compliance Programs," in an effort to "better harmonize" the document...more

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