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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
Hosted by the C5 Group Inc., the 2024 European Forum on Global Economic Sanctions will explore the evolution of the global economic sanctions landscape, analyzing everything from the shifting geopolitics around the globe, to...more
On March 14, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced its first enforcement case of the year and its first ever involving dealings with a Russian designated for sanctions...more
Part 1: US warns of serious risks of continuing business in Russia: key options for foreign investors - In its recent business advisory, dated 23 February 2024, the United States (“US”) Government warns businesses and...more
On February 28, 2024, President Biden issued a new Executive Order in order to better secure the private data of U.S. citizens from being exploited by foreign adversaries of the United States. By issuing his Executive Order...more
The U.S. Government recently announced the largest round of sanctions against the Russian Federation (Russia) since the invasion of Ukraine two years ago. This multi-agency effort enacted over 500 sanctions against foreign...more
In the last few years, changes to the United States enforcement stance on the forced labor import ban authorized by 19 U.S.C. § 1307 and passage of the Uyghur Forced Labor Prevention Act (UFLPA) have fundamentally changed the...more
The various and elusive tactics used by Russia to evade global sanctions and export controls have grown increasingly sophisticated over the last several months, putting the onus on multinational entities to become equally...more
Ensuring compliance with U.S. export controls, import regulations, and economic sanctions is common practice for companies that engage in international trade. These companies often have internal compliance policies and due...more
The United States manages more than three dozen separate economic and trade sanctions programs. Those programs target specified foreign governments along with thousands of named individuals, groups and entities in accordance...more
Key Points - On December 22, 2023, President Biden issued E.O. 14114 “Taking Additional Steps With Respect to the Russian Federation’s Harmful Activities.” Specifically, E.O. 14114, which amends E.O. 14024 and E.O. 14068,...more
On 22 December 2023, the Biden administration issued Executive Order 14114, “Taking Additional Steps with Respect to the Russian Federation’s Harmful Activities” (EO 14114), thereby amending EOs 14024 and 14068. The new EO...more
Immerse yourself in the only comprehensive economic sanctions event of its kind in Canada, spanning two days of invaluable insights and practical knowledge. Designed to cover U.S., EU, and major global sanctions, this...more
The landscape of financial crimes is constantly evolving, and the concept of transparency is being fundamentally challenged. A dynamic, innovative approach is imperative to preserve and shape the future of financial...more
Key Takeaways - On 17 November 2023, the Foreign, Commonwealth & Development Office (FCDO) and Office of Financial Sanctions Implementation (OFSI) published new guidance on Ownership and Control: Public Officials and...more
This Note is the second part of our look at regulatory expectations for sanctions compliance in the U.K. The first part of our review looked at Financial Conduct Authority (“FCA”) systems and controls requirements. The focus...more
Enforcement and legal risks relating to sanctions compliance remain high and all firms should continue to exercise care in meeting regulatory expectations. The promulgation of new sanctions relating to Russia has slowed but...more
On September 26, 2023, the “Export Enforcement Five” or “E5” partnership among the governments of Australia, Canada, New Zealand, the United Kingdom, and the United States issued joint guidance focused on preventing Russian...more
Football is an industry built on passion and commitment, with clubs steeped in tradition and soaked in the hopes and dreams of supporters captivated by the rollercoaster of emotions that professional sports can bring. It...more
With roughly 12,000 names now associated with the Specially Designated Nationals and Blocked Persons List (“SDN”), layered sanctions on activities with Russia, and growing sanctions on China activities, U.S. sanctions have...more
Updated guidance regarding the enforcement of financial sanctions from the UK’s Office of Financial Sanctions Implementation (OFSI) was published on 16 March 2023. The guidance, which sits alongside OFSI’s general guidance on...more
The UK’s Office of Financial Sanctions Implementation (OFSI) published updated guidance regarding the enforcement of financial sanctions on 16 March 2023. The guidance, which sits alongside OFSI’s general guidance on...more
The Office of Financial Sanctions Implementation (OFSI) has updated its ‘enforcement and monetary penalties for breaches of financial sanctions’ guidance, which was last updated in June 2022. ...more
On 16 March 2023, the Office of Financial Sanctions Implementation (“OFSI”) published updated guidance on enforcement and monetary penalties for breaches of financial sanctions (the “Guidance”). The Guidance now specifies...more
In the past year, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC), the U.S. Department of Commerce's Bureau of Industry and Security (BIS) and the U.S. Department of State's Directorate of...more