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Office of Foreign Assets Control (OFAC) Anti-Corruption

Foley & Lardner LLP

The Non-Compliant Cat in the Hat

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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

Bracewell LLP

Trump Administration Makes First Round of Cartel Foreign Terrorist Organization Designations with Focus on Mexico and Venezuela

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The US State Department has made its first round of designations pursuant to Executive Order 14157, “Designating Cartels and Other Organizations as Foreign Terrorist Organizations and Specially Designated Global Terrorists,”...more

Wiley Rein LLP

[Podcast] The Iron Fist of General Sani Abacha, Nigeria's Ruthless Dictator

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Join hosts Tatiana Sainati and Diana Shaw as they delve into the gripping story of General Sani Abacha, the Nigerian dictator who embezzled billions of dollars and ruled with an iron fist from 1993 to 1998. Known for his...more

Jenner & Block

Client Alert: Post-Conflict Reconstruction: Opportunities and Risks

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After years of destabilizing international and non-international armed conflict that has resulted in the loss of lives, destruction of communities, and decimation of economic opportunity in places across the globe, there are...more

The Volkov Law Group

OFAC Settles with Individual for $45,179 for Violations of the Global Magnitsky Act

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OFAC means what it says — in more ways than one.  In a precedent setting case, OFAC brought its first enforcement action against an individual for violating the Global Magnitsky Sanctions Regulations....more

The Volkov Law Group

The Sanctions Year in Review: DOJ takes First Steps to Enforce “The New FCPA” While OFAC’s Enforcement Actions Decline

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Enforcement and compliance prognosticators (like myself) continued to push DOJ’s promise to transform sanctions enforcement into the era of “the new FCPA.” While DOJ’s promise to bring about an aggressive corporate...more

Whiteford

Client Alert: DOJ and OFAC Actions Showcase Expansive U.S. Oversight of Foreign Conduct

Whiteford on

The U.S. Department of Justice (DOJ) and the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) have recently announced two enforcement actions that demonstrate the U.S. government's aggressive and...more

American Conference Institute (ACI)

FCPA, Export Controls, and Sanctions Enforcement: Adjusting Compliance Strategies for the New Normal

As the interplay between export controls, trade sanctions, and anticorruption enforcement continues to intensify, multinational companies must remain vigilant in ensuring that their compliance programs address the many...more

The Volkov Law Group

The Four Sanctions Compliance Cases that Everyone Should Know (Part I of IV)

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The Justice Department has repeated on several occasions that it intends to aggressively prosecute corporations for sanctions and export controls violations. The “New FCPA” is how the Justice Department characterizes its...more

The Volkov Law Group

OFAC Releases Guidance on Extended Statute of Limitations & Forthcoming Recordkeeping Changes

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The U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) has released updated guidance concerning recent legislation that doubled the statute of limitations for violations of certain sanctions and export control...more

The Volkov Law Group

Episode 328 -- Sanctions Enforcement Risks and Redlines

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In this new era of aggressive sanctions enforcement, companies have to understand the red lines that define where criminal and civil enforcement risk increase. In contrast to the history of FCPA enforcement, DOJ and OFAC...more

The Volkov Law Group

Supply Chain and Sanctions Compliance (Part III of IV)

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While OFAC’s enforcement actions and guidance points to important steps exporters must take when relying on third-party distributors and other intermediaries, the “reason to know” and affirmative obligations to monitor resale...more

The Volkov Law Group

Distribution Chains and Sanctions Compliance (Part II of IV)

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Companies rely on robust distribution chains as an efficient mechanism to enter new markets without requiring a significant investment.  Additionally, companies may maintain parallel sales activities in markets between their...more

The Volkov Law Group

DOJ, Commerce and Treasury Issue JCN on Foreign Person Liability for Sanctions and Export Controls Violations

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As DOJ, OFAC and BIS ramp up sanctions and export controls enforcement, they have continued to provide important compliance guidance.  You have to give the enforcement agencies credit — on the one hand, they regularly warn of...more

Adams & Reese

International Compliance Digest – March 2024

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International Compliance Digest is the new Adams and Reese monthly newsletter focused on international trade compliance and enforcement. Each month we will bring you the latest in compliance and enforcement updates, including...more

Wiley Rein LLP

Wiley's 10 Key Trade Developments: Evolution of Export Controls

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Along with engaging in closer cooperation with partner countries, the U.S. is prioritizing its own national security interests as well, moving first in many respects....more

Bracewell LLP

Lifting the Fog on the Foreign Corrupt Practices Act: Enforcement and Compliance Trends to Watch in San Francisco

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As lawyers, corporate executives and federal law enforcement officials prepare to gather this week in San Francisco for the ABA’s 39th National Institute on White Collar Crime, we offer our takeaways from January’s Houston...more

Ballard Spahr LLP

The American Front in Russia’s War on Ukraine: DOJ’s “Task Force KleptoCapture” Continues Focus on Operations of Sanctioned...

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We previously have blogged on actions taken by the DOJ’s “Task Force KleptoCapture,” an interagency law enforcement task force with a mandate to target sanctioned Russian and pro-Russian oligarchs. While explicitly launched...more

ArentFox Schiff

US Sanctions Hundreds More on Second Anniversary of Russia’s Invasion, Highlights Perils of Continuing Business in Russia, But...

ArentFox Schiff on

Two years after the start of Russia’s war in Ukraine and one week after the death of opposition politician and anticorruption activist Aleksey Navalny, the US government announced a new raft of sanctions and export controls...more

Wiley Rein LLP

Wiley’s Top 10 Trade Developments: Heightened Sanctions and Export Control Enforcement

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This week’s video comes from partner Lori Scheetz, who discusses heightened U.S. enforcement of sanctions and export control laws, including how the government is prioritizing the prosecution of evasion efforts and other...more

The Volkov Law Group

Preparing for the Storm — Effective Compliance in the New Sanctions Era (Part II of II)

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If companies operated with perfect governance mechanisms and controls, they would all be ready for the coming sanctions enforcement storm.  However, that is not the corporate reality.  Even after several companies are the...more

The Volkov Law Group

The Coming Corporate Sanctions Enforcement Storm (Part I of II)

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There are some things you learn best in calm, and some in storm.  Willa Cather I know I sound like a broken record.  The Justice Department’s white collar criminal enforcement  has been trending down over the last few...more

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

Episode 294 -- Catch Up on OFAC Enforcement: 3M and Emigrant Bank

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The past few weeks have not been kind to 3M. The company recently settled with the SEC for $6.5 million to resolve alleged FCPA violations related to its Chinese subsidiary’s dealings with Chinese state-owned healthcare...more

The Volkov Law Group

Reminder to file your 2023 Annual Report of Blocked Property: Due date September 30, 2023

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On September 22, 2023, the U.S. Department of Treasury Office of Foreign Assets Control (“OFAC”) issued its “Reminder to file your 2023 annual report of Blocked Property,” noting that entities or persons subject to the...more

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