In a bold move to tighten its sanctions enforcement, the EU rolled out Directive 2024/1226, establishing minimum rules for defining criminal offenses and penalties related to the violation of EU sanctions. Effective May 19,...more
On November 21, 2023, the U.S. Office of Foreign Assets Control (OFAC) announced its largest settlement in history with the virtual currency exchange Binance. This almost-billion dollar settlement is a part of a larger...more
11/27/2023
/ Anti-Money Laundering ,
CFTC ,
Civil Monetary Penalty ,
Compliance ,
Crypto Exchanges ,
Cryptocurrency ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
FinCEN ,
Money Laundering ,
Office of Foreign Assets Control (OFAC) ,
Sanction Violations ,
Settlement ,
Virtual Currency
On September 30, 2022, the Office of Foreign Assets Control (OFAC) published compliance guidance for instant payment systems. The guide highlights the need for emerging payment technology companies to assess their sanctions...more
With the advent of blockchain technology, vendors are increasingly accepting payments of goods, including artwork, with digital currency. The decentralized nature of digital currency makes it attractive for a lot of reasons,...more
A June 3, 2021 Executive Order (see our post here) designated 59 Chinese companies in which U.S. companies are prohibited from buying or selling securities. According to the Biden administration, those companies “threaten the...more
6/11/2021
/ Biden Administration ,
China ,
Compliance ,
Executive Orders ,
Foreign Investment ,
Geopolitical Risks ,
Investment Funds ,
Manufacturers ,
Securities ,
Startups ,
Supply Chain
Is your company in a high-risk zone? Does it have the following risk characteristics?
? Your company imports more than $10 million of goods.
? You are mid-market: between $50 million and $2 billion in annual turnover.
?...more
Ok, ok, don’t panic. Maybe not all of the millions of dedicated readers of this blog are in violation.
Nevertheless, as of June 1, if your company does business in France, it may be time to check your anticorruption...more
7/11/2017
/ Anti-Bribery ,
Anti-Corruption ,
Compliance ,
Deferred Prosecution Agreements ,
Extraterritoriality Rules ,
Fashion Industry ,
Foreign Corrupt Practices Act (FCPA) ,
France ,
Risk Management ,
Sapin II ,
UK Bribery Act
Ok, ok, don’t panic. Maybe not all of the millions of dedicated readers of this blog are in violation.
Nevertheless, as of June 1, if your company does business in France, it may be time to check your anticorruption...more
On August 30, 2015, the Washington Post broke a story that the Obama administration is developing a package of economic sanctions that will target Chinese companies and individuals who have benefitted from cybertheft. The new...more
9/18/2015
/ China ,
Compliance ,
Cyber Attacks ,
Cyber Crimes ,
Cyber Espionage ,
Cybertheft ,
Data Breach ,
Foreign Corporations ,
Hackers ,
National Security Agency (NSA) ,
Nuclear Power ,
Obama Administration ,
Sanctions ,
Search Engines ,
Source Code ,
Visas
In April 2015, the UK Bribery Act (UKBA) celebrated its fifth birthday. In the same month, the Serious Fraud Office brought a third round of corruption charges under the UKBA in the Alstom case. Those allegations, brought...more
5/20/2015
/ Alstom ,
Bribery ,
Chief Compliance Officers ,
Compliance ,
Corruption ,
Department of Justice (DOJ) ,
Government Investigations ,
Plea Agreements ,
Serious Fraud Office (SFO) ,
Suspensions & Debarments ,
UK ,
UK Bribery Act
In Episode I: The Basics we noted that U.S. Export Control Reform may be causing confusion and consternation among those who will have to take the first theoretical rule changes and apply them in real and practical...more
On April, 30, 2013, Raytheon Company, a major military electronics and weapons manufacturer, agreed with the U.S. Department of State to pay $8 million in civil penalties and remedial expenditures to settle alleged violations...more
Since 2011, President Barack Obama’s administration has actively pursued export control reform designed to reduce the regulatory burdens on U.S. companies and enhance U.S. national security (as reported here). On March 7,...more