Latest Publications

Share:

District Court Rejects Challenges to ITAR Criminal Charges

On July 9, 2024, District Judge David Hale in Kentucky denied motions to dismiss and motions to suppress filed by four defendants against a criminal case involving ITAR charges for illegal exports of sensitive,...more

SEC Expands Internal Controls Provision to Cover Cybersecurity Incidents and Reaches $2.1 Million Settlement with R.R. Donnelley &...

In a significant expansion of internal controls enforcement, the SEC announced a $2.1 million settlement with R.R. Donnelley & Sons Co. (“RRD”) for its handling of a 2021 ransomware attack and resulting disclosure failures. ...more

Episode 329 -- Bryn Sedlacek from Aravo on TPRM Holistic Risks and Unified Visibility [Audio]

Bryn Sedlacek, Vice President, Product Manager at Aravo, joins us on the podcast to discuss third-party risk management with a focus on holistic risks and unified visibility. In a wide-ranging discussion, Mike Volkov and Bryn...more

Supreme Court Continues to Pare Back Criminal Laws

In a pair of rulings issued near the end of the last Term, Fischer v. United States and Snyder v. United States, the Supreme Court continued to cut back on the Justice Department’s interpretation and enforcement of criminal...more

Supreme Court Strikes Down Chevron Deference Rule

In a historic decision, the Supreme Court struck down the forty-year-old agency deference rule established in Chevron v. Natural Resources Defense Council.  In two separate decisions, the Supreme Court ruled in Loper Bright...more

Episode 328 -- Sanctions Enforcement Risks and Redlines [Audio]

In this new era of aggressive sanctions enforcement, companies have to understand the red lines that define where criminal and civil enforcement risk increase. In contrast to the history of FCPA enforcement, DOJ and OFAC...more

Supreme Court Rules SEC’s In-House Adjudication Is Unconstitutional

In a recent decision, Securities and Exchange Commission v. Jarkesy, the Supreme Court voted 6-3 to reject the Securities and Exchange Commission’s use of in-house administrative proceedings to adjudicate securities fraud...more

Episode 327 -- Another Look at the Importance of Corporate Culture [Audio]

LRN has issued another important report -- in its latest report, The 2024 Benchmark of Ethical Culture Report, LRN has focused on the critical issue of corporate culture. LRN is a pacesetter and the leader in reliable...more

OFAC Settles with Mondo TV for $538k for Violation of North Korean Sanctions

OFAC has been busy and not so busy — what do I mean? OFAC is administering a complex set of coordinated sanctions against Russia, in close coordination with the EU and the UK....more

Episode 326 -- Dottie Schindlinger on Diligent's Report on Board Oversight of Cybersecurity Risks and Performance [Audio]

Dottie Schindlinger is Executive Director of Diligent Institute, the global corporate governance research arm of Diligent - the largest SaaS software company in the Governance, Risk, Compliance (GRC), and ESG space. Diligent...more

Is Your Sanctions Compliance Program Compliant? — A Quick Five-Question Quiz

Checklists can be handy — by simplifying and focusing on specific issues, a checklist can organize thinking and prioritize tasks. Here are five (5) questions that are fairly simple but revealing as to whether a company’s...more

Episode 325 -- AI and Emerging Compliance Frameworks [Audio]

A new compliance cottage industry surrounds artificial intelligence. We are at such an early stage of AI development, and companies are still figuring out how they can employ the technology. However, some industries, such as...more

Sanctions Enforcement on the Outer Edges of Trade Activity (Part II of II)

We all know what a “core” sanctions violation looks like.  The heartland of such misconduct has been described on numerous occasions in OFAC enforcement actions and settlements.  In this environment, however, companies have...more

Sanctions Compliance: Understanding the Red Lines of Enforcement (Part I of II)

In this new era of aggressive sanctions enforcement, companies have to understand the red lines that define where criminal and civil enforcement risk increase.  In contrast to the history of FCPA enforcement, DOJ and OFAC...more

LRN’s Call to Action: 5 Steps Every Company Should Take to Promote an Ethical Culture (Part II of II)

LRN’s  research consistently paints a picture that every board member, senior executive and middle manager should view — corporate culture is an organization’s most valuable intangible asset and is a significant determinant...more

Episode 324 -- Third-Party Risks and Sanctions Compliance [Audio]

With the beginning of the “New FCPA” era coined by DOJ’s Deputy Attorney General Lisa Monaco, we now need to focus on third-party risk and sanctions enforcement. The law, the practice, and the risks are important and not just...more

LRN Report Highlights (Again) the Importance of Ethical Culture (Part I of II)

In its latest report, The 2024 Benchmark of Ethical Culture Report, LRN has focused on the critical issue of corporate culture.  LRN is a pacesetter and the leader in reliable studies on complex ethics and compliance issues....more

AI Compliance Programs: Filling in the Gaps and Mitigating Risks (Part II of II)

We are at an important inflection point — AI technologies are rapidly developing; we are witnessing a historic metamorphosis in the technology, the impact on businesses and society and important steps being taken to regulate...more

Emerging AI Risk and Compliance Frameworks (Part I of II)

The new compliance cottage industry surrounds artificial intelligence.  We are at such an early stage of AI development — companies are still figuring out how they can employ the technology.  Some industries, such as...more

Congress Extends Sanctions Statute of Limitations And Addresses Other National Security Issues

On April 24, 2024, President Biden signed into law a sweeping national security legislative package that included the 21st Century Peace Through Strength Act, which includes measures to promote sanctions and export controls...more

Life Sciences Company Escapes Criminal Charges for Employee’s Illegal Export Scheme

Sigma-Aldrich, Inc., d/b/a MilliporeSigma (“MilliporeSigma”), a U.S. life sciences company based in Massachusetts, escaped criminal charges for export control violations, despite a former sales person’s scheme to illegally...more

The Magnificent Seven: Important Ways to Mitigate Your Third-Party Sanctions Risks (Part IV of IV)

It may seem like a Herculean task — but it can be done.  I regularly opine that mitigating sanctions risks for your third-party population is an easier task than doing so for your anti-corruption risks.  One big reason —...more

Supply Chain and Sanctions Compliance (Part III of IV)

While OFAC’s enforcement actions and guidance points to important steps exporters must take when relying on third-party distributors and other intermediaries, the “reason to know” and affirmative obligations to monitor resale...more

Distribution Chains and Sanctions Compliance (Part II of IV)

Companies rely on robust distribution chains as an efficient mechanism to enter new markets without requiring a significant investment.  Additionally, companies may maintain parallel sales activities in markets between their...more

The Same Old Song with a Different Meaning — Third-Party Risks and Sanctions Compliance (Part I of IV)

Sorry to start a four-part series with a reference to music from our long-ago past.  The Four Tops sang the “Same Old Song, with a Different Meaning” (released in 1965). So, how does that relate to third-party risks?  Well,...more

2,725 Results
 / 
View per page
Page: of 109

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
- hide
- hide