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Internal Controls Office of Foreign Assets Control (OFAC) Ethics

Foley & Lardner LLP

The Non-Compliant Cat in the Hat

Foley & Lardner LLP on

So, just before Easter, in 1957, a little book you may have heard of, called The Cat in the Hat, made its first appearance. Theodore Geisel — writing under the name “Dr. Suess” — later said that of all his children’s books,...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

Putting Together Your Sanctions Compliance Program: Management Commitment (Part I of IV)

The Volkov Law Group on

If you follow my blog, you know I am not one to embrace hyperbole.  So, forgive me for stretching a little here, but the OFAC Framework for Sanctions Compliance Programs is a game changer.  Let me explain why I am saying...more

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