Podcast: Illinois Tool Works Inc. & Subsidiaries v. Commissioner of Internal Revenue
FCPA Compliance and Ethics Report-Episode 142-Reflections on the Goodyear FCPA Enforcement Action
FCPA Compliance and Ethics Report-Episode 122-with Matt Kelly on Alstom, Avon and Petrobras
FCPA Compliance and Ethics Report-Episode 117-the Avon FCPA Enforcement Action
Cross-Border Update on Investing and Doing Business in the United States
C.H. Robinson International Inc. (CHR), a Minnesota-based global transportation and logistics company, has agreed to pay $257,690 to settle civil liability for 82 apparent violations of sanctions against Iran and Cuba...more
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
ACI is excited to welcome you back in-person to the 14th Advanced Forum on FCPA & Anti-Corruption for the Life Sciences Industry, taking place on July 21–22, 2022 in Boston! Legal and compliance professionals from...more
Economic sanctions have been increasingly used by countries and international organizations as a tool of foreign policy and national security. This increase in the use of sanctions, particularly by the U.S. Department of the...more
This week, the Office of Foreign Assets Control (OFAC) announced a settlement agreement with Berkshire Hathaway Inc. involving apparent violations of the U.S. embargo on Iran by a subsidiary in Turkey. Under the agreement,...more
Learning objectives: - Overview of US sanctions regimes - To whom US laws apply (e.g. includes foreign subsidiaries; secondary sanctions) - key developments - compliance obligations and elements of an effective sanctions...more
On May 2, 2019, OFAC (Office of Foreign assets Control) published guidance titled “A Framework for OFAC Compliance Commitments”. The purpose of the OFAC Framework guidance is to encourage a “risk-based” approach to...more
On June 13, 2019, OFAC announced a settlement with Expedia Group, Inc. for violations of the Cuban Assets Control Regulations (“CACR”). (Available here). Expedia’s foreign subsidiaries assisted more than 2,200 individuals...more
On March 27, 2019, the Office of Foreign Assets Control (OFAC) announced a settlement agreement with US-based Stanley Black & Decker, Inc., (Stanley Black & Decker) and its foreign subsidiary, Jiangsu Guoqiang Tools Co., Ltd....more
A U.S. company was recently charged with major sanctions violations when its foreign subsidiary entered business transactions with a party listed on the Specially Designated Nationals List. This is a reminder of the...more
The Trump Administration issued a new executive order on August 6, 2018, in order to reimpose the first tranche of the Iran sanctions lifted by the former Joint Comprehensive Plan of Action (“JCPOA”). ...more
On May 8, President Trump announced that the United States is withdrawing from the multilateral nuclear accord with Iran known as the Joint Comprehensive Plan of Action (JCPOA). The U.S. will reimpose sanctions suspended...more
On April 6, 2018, the Office of Foreign Assets Control (OFAC) of the U.S. Treasury Department sanctioned a number of Russian businessmen and companies, as well as Russian government officials and two state-owned entities. The...more
Many companies supply goods and services through third party distributors. When well-structured, the use of distributors can shift some of the cost and compliance risk of selling products outside of your home territory. But...more
A recent settlement agreement between the Office of Foreign Asset Control (OFAC) and BD White Birch Investment LLC, a U.S.-based paper company, is an important reminder that U.S. companies cannot assist their foreign...more
On June 8, the Office of Foreign Assets Control (OFAC) announced a monetary penalty against American Honda Finance Corporation (American Honda) for alleged violations of the Cuban Assets Control Regulations (CACR), the...more
- Canadian bank pays penalties for U.S. dollar transactions involving Cuba and Iran - Bank receives Finding of Violation – but no penalty – for violations by European subsidiaries - Disclosure and cooperation...more
With the rise of OFAC Sanctions enforcement and compliance issues, companies have to devote significant resources to following changes in OFAC Sanctions. Over the last few years, the US government has significantly altered...more