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Enforcement Guidance Internal Controls

Cozen O'Connor

CFTC Issues New Guidance Prioritizing Compliance Programs in Enforcement Decisions

Cozen O'Connor on

On September 10, 2020, the Commodity Futures Trading Commission (the CFTC) issued a new guidance memorandum outlining factors that the Division of Enforcement (the division) will consider when evaluating compliance programs...more

The Volkov Law Group

Conducting a Sanctions Risk Assessment: A New Era for Analyzing Your Risks (Part II of IV)

The Volkov Law Group on

OFAC’s new framework guidance for sanctions compliance programs stretched into new territory with its risk assessment requirement.  This new approach reflects OFAC’s recent aggressive enforcement programs....more

The Volkov Law Group

OFAC Joins the Compliance Club – Issues Framework for Sanctions Compliance Programs (Part I of IV)

The Volkov Law Group on

On the heels of the Justice Department’s announcement of its new compliance guidance, on May 2, 2019, the Treasury Department’s Office of Foreign Asset Control (“OFAC”) issued its promised guidance for sanctions compliance...more

Perkins Coie

DOJ Offers Big Incentive to Healthcare Industry to Self-Disclose Criminal Conduct

Perkins Coie on

The U.S. Department of Justice (DOJ) announced a “road map” for the healthcare industry last month to guide voluntary self-disclosures and cooperation with government investigations. Speaking at the annual American Health...more

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