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Compliance Department of Justice (DOJ) Economic Sanctions

Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory violations. ... more +
Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory violations.  In response to many corporate scandals evidencing rampant unethical business practices, many nations, including the United States, began passing strict regulatory frameworks aimed at curbing these abuses. Notable pieces of legislation in this area include the U.S. Foreign Corrupt Practices Act (FCPA), Sarbanes-Oxley (SOX), and the U.K. Bribery Act, to name a few. The foregoing statutes and the severe penalties often associated with them form the basis of many modern institutional compliance programs. less -
Adams and Reese LLP

International Compliance Digest – August 2024

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August was another robust month in international trade that further signifies the need for corporations to invest in effective compliance programs. For starters, the DOJ unveiled a new program that incentivizes corporate...more

The Volkov Law Group

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

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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

Adams and Reese LLP

International Compliance Digest – May 2024

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May saw the long-awaited release of the USTR’s Section 301 review. USTR confirmed that the Trump-era tariffs will remain in place, and raised those tariffs by another $18 billion on manufacturing, critical minerals, solar...more

The Volkov Law Group

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

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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

Womble Bond Dickinson

DOJ Enhancing Its Sanctions Toolkit

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President Biden recently signed a foreign aid bill that will have significant implications for United States sanctions enforcement, specifically Section 206 of the International Emergency Economic Powers Act (50 U.S.C. 1705)...more

BakerHostetler

Key Sanctions Developments During the First Quarter of 2024

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During the first quarter of 2024, there were significant developments in the U.S. sanctions framework. This report summarizes the key developments and provides links to the relevant sources....more

Foley Hoag LLP - White Collar Law &...

Enforcement of U.S. Trade Sanctions and Export Controls in 2023 and What to Expect In 2024

This is the tenth in our 2024 Year in Preview series examining important trends in white collar law and investigations in the coming year. Our previous post, "Health Care Fraud Enforcement in 2024," can be found here....more

The Volkov Law Group

DOJ, Commerce and Treasury Issue JCN on Foreign Person Liability for Sanctions and Export Controls Violations

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As DOJ, OFAC and BIS ramp up sanctions and export controls enforcement, they have continued to provide important compliance guidance.  You have to give the enforcement agencies credit — on the one hand, they regularly warn of...more

Adams and Reese LLP

International Compliance Digest – March 2024

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International Compliance Digest is the new Adams and Reese monthly newsletter focused on international trade compliance and enforcement. Each month we will bring you the latest in compliance and enforcement updates, including...more

Pillsbury Winthrop Shaw Pittman LLP

Non-U.S. Companies on Alert: U.S. Government Issues Tri-Seal Compliance Note on Global Enforcement

New Tri-Seal Compliance Note highlights sanctions and export control compliance expectations for non-U.S. persons. Three agencies overseeing U.S. trade law compliance provided an overview of where U.S. sanctions and export...more

Holland & Knight LLP

New Tri-Seal Compliance Note Issued to Non-U.S. Persons

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The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC), U.S. Department of Commerce's Bureau of Industry and Security (BIS) and U.S. Department of Justice (DOJ) on March 6, 2024, issued a Tri-Seal...more

Adams and Reese LLP

Beyond Borders: Navigating Global Business Compliance with the FCPA

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On March 7th, the Department of Justice (DOJ) announced a new whistleblower reward program intended to help prosecutors bring more foreign corruption cases. Under the new program, individuals who report corporate misconduct...more

Morrison & Foerster LLP

Tri-Seal Compliance Note Stresses Importance of Non-U.S. Persons Complying with U.S. Sanctions and Export Control Laws

On March 6, 2024, the U.S. Departments of Commerce, Justice, and the Treasury issued a Tri-Seal Compliance Note (Compliance Note) stressing the need for non-U.S. persons to comply with U.S. sanctions and export controls. The...more

Torres Trade Law, PLLC

U.S. Government to Foreign Persons: Comply with Economic Sanctions and Export Control Laws

In a move that highlights the U.S. government’s ongoing fight against evasion of sanctions and export control laws, the Departments of the Treasury, Commerce, and Justice yesterday published yet another Tri-Seal Compliance...more

The Volkov Law Group

Preparing for the Storm — Effective Compliance in the New Sanctions Era (Part II of II)

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If companies operated with perfect governance mechanisms and controls, they would all be ready for the coming sanctions enforcement storm.  However, that is not the corporate reality.  Even after several companies are the...more

The Volkov Law Group

The Coming Corporate Sanctions Enforcement Storm (Part I of II)

The Volkov Law Group on

There are some things you learn best in calm, and some in storm.  Willa Cather I know I sound like a broken record.  The Justice Department’s white collar criminal enforcement  has been trending down over the last few...more

American Conference Institute (ACI)

[Event] 18th Annual Flagship Conference on Economic Sanctions Enforcement and Compliance - April 29th - 30th, Washington, DC

For over eighteen years the “who’s who” in the global sanctions’ community has attended 18th Annual Flagship Conference on Economic Sanctions Enforcement and Compliance– which is widely regarded as the premier conference for...more

Venable LLP

Freight Forwarders and Common Carriers: As You Look Ahead to 2024, Do You "Know Your Cargo"?

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As federal regulators have recently made clear, steamship lines, non-vessel-operating common carriers, indirect air carriers, freight forwarders, and others involved in the global movement of cargo must ensure that their...more

Lowenstein Sandler LLP

Trade Matters - Lowenstein Sandler's Global Trade & National Security Newsletter - January 2024

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On December 11, the Department of Justice, the Department of Commerce’s Bureau of Industry and Security (BIS), the Department of Homeland Security, the Department of State’s Directorate of Defense Trade Controls (DDTC), and...more

Seward & Kissel LLP

“Quint-Seal” Compliance Note Highlights Intensifying U.S. Government Enforcement of Sanctions and Export Control Laws in the...

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On December 12, 2023, the Department of Justice (DOJ), Department of Commerce’s Bureau of Industry and Security (BIS), Department of Homeland Security’s Homeland Security Investigations (HSI), the Department of State’s...more

The Volkov Law Group

U.S. Government Charges Parties with Violating U.S. Sanctions and Export Control Laws

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As we have repeatedly noted in the context of other blog posts and webinars in which various representatives of The Volkov Law Group have participated, the violation of existing U.S. sanctions and export control regulations...more

NAVEX

The Subtle but Significant Shift at U.S. Justice Department

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In October, deputy attorney general Lisa Monaco made headlines when she announced a new leniency policy at the U.S. Justice Department for companies that disclose compliance violations discovered during mergers and...more

Sheppard Mullin Richter & Hampton LLP

Binance’s Paper Compliance Program Crumples Under OFAC Scrutiny in Largest OFAC Settlement in History

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

Foley & Lardner LLP

International Trade, Enforcement & Compliance Recent Developments Update (November 16, 2023)

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Did you know that whistleblowers can use the False Claims Act to get the U.S. Government to investigate allegations of lost revenue to the U.S. Treasury, including underpaid Customs tariffs? A large importer recently found...more

American Conference Institute (ACI)

Navigating U.S. Sanctions and Export Control Restrictions

Over the last several months, companies have become entangled in an increasingly complex web of new and expanded sanctions and export control restrictions related to Russia in response to its war on Ukraine. The current...more

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