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Office of Foreign Assets Control (OFAC) Corporate Management

The Volkov Law Group

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

The Volkov Law Group on

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

NAVEX

A Review of Risk & Compliance in 2022

NAVEX on

As 2022 comes to a close, now is an ideal time to reflect on the developments and challenges this year held for the risk and compliance profession – and there was no shortage of either. The complexity of maintaining...more

The Volkov Law Group

Troubling Trends: The CCO’s Authority, Independence and Access to Resources (Part II of III)

The Volkov Law Group on

While my first posting highlighted the positive developments in the CCO’s role and professional development, the next two postings present troubling concerns....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

Thomas Fox - Compliance Evangelist

The OFAC Compliance Framework: Element 1 – Management Commitment

Yesterday, while honoring Ginger Baker who passed away this weekend, I began a multipart series on the Framework for OFAC Compliance Commitments (Framework). Mike Volkov has called this Framework a “game-changer” and has...more

Eversheds Sutherland (US) LLP

Recent guidance brings OFAC in line with domestic and global compliance trends

On May 2, 2019, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued guidance titled “A Framework for OFAC Compliance Commitments” (Guidance), providing direction regarding what OFAC considers to...more

Latham & Watkins LLP

OFAC’s 5 Essential Components of an Effective Sanctions Compliance Program

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OFAC outlines baseline considerations for evaluating a risk-based sanctions compliance program. On May 2, 2019, the US Treasury Department’s Office of Foreign Assets Control (OFAC) published A Framework for OFAC Compliance...more

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