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Office of Foreign Assets Control (OFAC) Internal Controls

Foley & Lardner LLP

What Every Multinational Company Should Know About . . . Implementing an International Compliance Program (Part I)

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Record penalties for violations of U.S. regulations governing international conduct and transactions illustrate the risk of costly enforcement actions facing multinational companies. Yet, many multinational companies lack...more

The Volkov Law Group

Refreshing and Elevating Your Sanctions Compliance Program (Part II of III)

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Let’s move beyond the headline – trade compliance is the new FCPA.  We get it.  The next step is to do something about it.  The Justice Department has repeated this refrain – it is one of its greatest hits.  In addition, DOJ,...more

Holland & Knight LLP

Restraining the Kraken: Another Crypto Company Under OFAC Scrutiny

Holland & Knight LLP on

The U.S. Department of the Treasury's Office of Foreign Asset Control (OFAC) on Nov. 28, 2022, announced a more than $362,000 settlement with Payward Inc. d/b/a Kraken (Kraken), a Delaware-incorporated company that offers...more

Bracewell LLP

Check It Once, Check It Twice: OFAC Requests Daily Screenings of SDN List for Sanctions Compliance

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A recent OFAC enforcement action against MidFirst Bank highlights the five essential components of an effective sanctions compliance program that will serve to mitigate exposure in the event of a violation: Senior...more

American Conference Institute (ACI)

[Event] FCPA & Anti-Corruption for the Life Sciences Industry - July 21st - 22nd, Boston, MA

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

The Volkov Law Group

Global Logistics Company Settles OFAC Violations for $6.1 Million

The Volkov Law Group on

You have to wonder how OFAC has the time to investigate and settle cases given its significant work implementing the Russia Sanctions Program.  But OFAC continues to demonstrate its commitment to aggressive enforcement. ...more

Guidepost Solutions LLC

Is Your Russia–Ukraine And Overall Sanctions Compliance Program Really Working? (Don’t Find Out the Hard Way)

How do you know if your sanctions compliance program (“SCP”) is really working? Can your firm really afford to find out the hard way – violations with major penalties, especially after regulators uncover your management did...more

The Volkov Law Group

OFAC Settles with Hong Kong Trading Company for $5.2 Million for Violations of Iran Sanctions Program

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OFAC is off to a quick start in 2022.  After announcing its Airbnb enforcement action in the beginning of January, OFAC announced a settlement with Sojitz (Hong Kong) Limited, a Hong Kong, China-based company that engages in...more

Bass, Berry & Sims PLC

OFAC Enforcement Update: Settlements Show Value of Internal Controls, Disclosure

Bass, Berry & Sims PLC on

On December 23, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) and TD Bank, N.A. (TD) reached a settlement to resolve TD’s violations of the North Korea Sanctions Regulations and the...more

Skadden, Arps, Slate, Meagher & Flom LLP

US Treasury Provides Detailed Guidance for the Virtual Currency Industry on Sanctions Compliance

On October 15, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued detailed guidance to the virtual currency industry, putting virtual currency companies on notice of the ways OFAC...more

Foodman CPAs & Advisors

OFAC Puts Virtual Currency Industry on Notice

In a new Sanctions Compliance Guide, The Office of Foreign Assets Control (OFAC) of the U.S. Treasury reiterates that compliance obligations apply equally to transactions involving virtual currencies and those involving...more

Kramer Levin Naftalis & Frankel LLP

OFAC Issues Sanctions Compliance Guidance for Virtual Currency Industry

On Oct. 15, 2021, the Treasury Department’s Office of Foreign Assets Control (OFAC) published sanctions compliance guidance for the virtual currency industry. OFAC acknowledged that virtual currencies are playing an...more

A&O Shearman

Sanctions Compliance Guidance for the Virtual Currency Industry and updated frequently asked questions

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In response to the rapid growth of virtual currencies, the Treasury Department’s Office of Foreign Assets Control (“OFAC”) recently published Sanctions Compliance Guidance for the Virtual Currency Industry (“Guidance”)....more

Proskauer - Blockchain and the Law

Treasury Department Steps Up Its Counter-Ransomware Efforts and Simultaneously Issues New Sanctions Compliance Guidance for...

Recently, the Financial Crimes Enforcement Network (FinCEN), a bureau of the U.S. Treasury Department, released a report on ransomware trends stating that during the first half of 2021, 68 different ransomware variants...more

King & Spalding

OFAC Puts Virtual Currency Industry On Notice

King & Spalding on

Guidance Demonstrates OFAC’s Expectations for Sanctions Compliance by Cryptocurrency Industry - On October 15, 2021, the Office of Foreign Assets Control (“OFAC”) of the U.S. Department of the Treasury published Sanctions...more

K2 Integrity

Treasury Releases Guidance for the Virtual Currency Industry and Analysis on Ransomware Trends

K2 Integrity on

Office of Foreign Assets Control (OFAC) released detailed sanctions compliance guidance for the virtual currency industry (the Guidance). The Guidance provides an overview of OFAC sanctions requirements and lists several best...more

The Volkov Law Group

The Elevation of Sanctions Compliance

The Volkov Law Group on

This has been  an interesting enforcement year.  The Biden Administration promised a renewal of aggressive enforcement. The difficult transition from the last administration and political resistance to confirmation of...more

Nossaman LLP

How to Prevent an OFAC Sanction When Responding to a Ransomware Attack

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A ransomware attack is a major threat affecting all sectors of business, including healthcare. Organizations typically follow state and federal privacy laws as part of their ransomware prevention and response measures....more

Womble Bond Dickinson

Administration's Anti-Corruption Efforts Likely to Yield Greater FCPA Enforcement in Latin America and Beyond

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On June 3 of this year, the Biden Administration made plain its commitment to fighting corruption around the world, releasing a document identifying the fight against corruption “as an economic and national security priority”...more

K2 Integrity

SPACs and Sanctions: Due Diligence Considerations

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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

K2 Integrity

What the Biden Administration Brings on Sanctions

K2 Integrity on

Despite a shift in the sanction landscape, it will take time for enforcement activity to catch up. As a result, organizations should regularly examine their exposure with business partners around the globe and consult with...more

Foodman CPAs & Advisors

Trabajando juntos, los abogados y los contadores forenses pueden brindar soluciones óptimas

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Existe una propuesta de valor presentable a un cliente cuando un abogado trabaja en conjunto con un contador forense.  Los litigios a menudo implican la superposición de múltiples y complejos asuntos legales y contables....more

Foodman CPAs & Advisors

Working together, Attorneys and Forensic Accountants Can Bring About Optimal Solutions

Foodman CPAs & Advisors on

There is a value added for a client when an Attorney is working in tandem with a forensic accountant. Litigation often involves overlapping complex accounting and legal issues. Working together, Attorneys and Forensic...more

The Volkov Law Group

Gatekeeper Misfires and Corporate Governance Failures

The Volkov Law Group on

Here is another obvious point – internal controls are intended to ensure compliance with relevant policies and procedures.  Internal controls are not just for show, or not just limited to financial reporting.   A compliance...more

The Volkov Law Group

Five Basic Steps to Implement a Sanctions Compliance Program

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Companies have to implement a sanctions compliance program (SCP).  When I use the term SCP, I mean much more than just having one employee screen a customer before a shipment is sent.  Too many companies are behind the 8-ball...more

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