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Office of Foreign Assets Control (OFAC) Anti-Corruption Compliance

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

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

The Volkov Law Group on

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

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

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

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

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

The Volkov Law Group on

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

The Volkov Law Group

Five Practical Steps to Elevate Your Sanctions Compliance Program (Part III of III)

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Even with the current focus on sanctions compliance, many companies have done little to assess and enhance their existing sanctions compliance program.  Instead, a number of companies have stitched together a basic sanctions...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

Skadden, Arps, Slate, Meagher & Flom LLP

New US Efforts To Prosecute Sanctions Evasion and Export Control Violations May Require Compliance Programs To Be Updated

DOJ Increases Resources To Investigate and Prosecute Sanctions Evasion and Export Control Violations - On March 2, 2023, during a keynote speech at the American Bar Association’s annual White Collar Crime National...more

The Volkov Law Group

DOJ, and Departments of Commerce and Treasury Issue Joint Compliance Note on Evasion of Russia Sanctions and Export Controls

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As we have noted on numerous occasions, the U.S. Russia Sanctions and Export Control Program is unprecedented and a compliance challenge for all organizations. In another unprecedented action, the Justice Department and the...more

Perkins Coie

DOJ Announces Shift Toward Corporate Enforcement for Sanctions and Export Control Violations

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Deputy Attorney General (DAG) Lisa Monaco once again delivered groundbreaking remarks at the American Bar Association (ABA) National Institute on White Collar Crime (ABA White Collar Conference) on March 2, 2023, this time...more

Woodruff Sawyer

OFAC Sanctions: Avoiding Unintentional Violations

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Are you a US-headquartered company with international business operations? How confident are you that your company and its agents, employees, affiliates, or subsidiaries are not dealing with foreign countries, geographic...more

The Volkov Law Group

Commerce Department Tacks to New Aggressive Enforcement Program

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The Commerce Department’s Bureau of Industry and Security (“BIS”) has decided to join the enforcement club.  BIS’s recent announcement of new policies to administrative actions should not be surprising.  ...more

American Conference Institute (ACI)

Compliance measures to address sanctions enforcement: ‘the new FCPA’

In line with the Biden administration’s declaration last year that anticorruption is a “core United States national security interest,” sanctions evasion enforcement rapidly has become a core priority for the Department of...more

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