News & Analysis as of

Office of Foreign Assets Control (OFAC) Corporate Misconduct Compliance

Oberheiden P.C.

10 Important Facts About FinCEN’s Whistleblower Program

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The Financial Crimes Enforcement Network (FinCEN) is one of a handful of federal authorities that have adopted whistleblower programs focused on facilitating enforcement in hard-to-target areas. While FinCEN focuses its...more

The Volkov Law Group

Family International and Owner Pay $1.07 Million to Settle Violations of Russia Sanctions Program

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Family International, a Florida real estate company, and its U.S. owner, Roman Sinyavsky, settled with  OFAC for $1.07 million for 73 violations of the Russia Sanctions program.  In a separate criminal case, Roman Sinyavsky...more

Guidepost Solutions LLC

Monitoring Against Whistleblower Retaliation

Guidepost Solutions LLC on

Saves Lives, Prevents Major Crimes, and Accelerates Voluntary Self - Disclosures The U.S. Department of Justice (“DoJ”) recently spotlighted its Whistleblower Awards Program and Voluntary Self Disclosure (“VSDs”)...more

Guidepost Solutions LLC

3 Key Factors in Safeguarding National Security: Economic Sanctions, Voluntary Self-Disclosures, and Whistleblower Retaliation

Companies and their executives can reduce Department of Justice (DoJ), OFAC, and Commerce Department risks (and liability) by understanding and respecting the relationship between economic sanctions, voluntary...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

Akin Gump Strauss Hauer & Feld LLP

Federal Agency Settlements with Wells Fargo Illustrate Sanctions Risks Involving IT Systems

Key Points - On March 30, 2023, OFAC announced a settlement agreement with Wells Fargo for 124 apparent violations of three different sanctions programs (Iran, Syria and Sudan), all related to a legacy Wachovia Bank...more

The Volkov Law Group

Wells Fargo Fumbles Sanctions Compliance Demonstrating An Absence of Culture of Compliance (Part II of II)

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Not that I am a glutton for punishment, but I always find enforcement actions to supply a number of valuable lessons learned. There are always instructive nuggets of information, opportunities missed, and root causes that...more

The Volkov Law Group

Navigating DOJ and OFAC Voluntary Disclosures for Sanctions Violations

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The Department of Justice is pushing its commitment to voluntary disclosure programs.  Companies, however, are not lining up at DOJ’s door.  The balance between sitting tight or voluntary disclosures requires care....more

Skadden, Arps, Slate, Meagher & Flom LLP

Compliance in a Time of Crisis

Addressing the Evolving Risks - Warren Buffett said that “only when the tide goes out do you discover who’s been swimming naked.” Buffett was not talking about compliance programs in a time of crisis, but his wisdom applies...more

The Volkov Law Group

Swiss Telecomm Company Pays $7.8 Million to Settle OFAC Sanctions Violations

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OFAC continues to aggressively enforce its sanctions programs.  In its latest enforcement action, OFAC agreed with Société Internationale de Télécommunications Aéronautiques SCRL (“SITA”), a Swiss telecom company, to an...more

Thomas Fox - Compliance Evangelist

Introducing New 2020 Podcast Series – 31 Days to a More Effective Compliance Program

2019 has been a very significant year for every compliance practitioner and compliance program. There were three significant releases of information by the federal government which directly impacted compliance professionals...more

The Volkov Law Group

UK Bank Agrees to Pay $4 Million to Settle OFAC Sudanese Sanctions Violations

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Last week, British Arab Commercial Bank (BACB), located in the United Kingdom, agreed to settle an OFAC enforcement action for $4 million. ...more

The Volkov Law Group

Catching Up with OFAC Sanctions Enforcement Actions

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OFAC is clearly sending a message about sanctions enforcement and compliance responsibilities.  OFAC is aggressively seeking out new targets for enforcement.  OFAC continues to focus on Iran, Cuba, Venezuela and North Korea,...more

The Volkov Law Group

Watching the River Flow: The Evolution and Future of Compliance (Part I of III)

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Bob Dylan, Watch the River FlowI have to admit it – I still love to listen to Bob Dylan.  With age, his lyrics resonate more and more.  HERE is a nice version of Watch the River Flow in case you want to listen while reading...more

Sheppard Mullin Richter & Hampton LLP

Feds Focus on Individuals in Evaluating Corporate Compliance Programs

Earlier this month, the U.S. Department of Justice (“DOJ”) and the U.S. Department of the Treasury’s Office of Foreign Asset Controls (“OFAC”) both issued guidance regarding their expectations for corporate compliance...more

The Volkov Law Group

OFAC Framework for Sanctions Compliance Programs – Testing and Auditing and Training (Part III of IV)

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OFAC’s new Framework for Sanctions Compliance Programs incorporates a number of important principles from Justice Department and US Sentencing Guideline requirements for effective compliance programs. ...more

Baker Donelson

Update on Regulatory Compliance in the Global Health Care Industry

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A comprehensive understanding of the constantly evolving layers that make up federal anti-corruption statutes, sanctions regulations and export control restrictions is imperative for both the pharmaceutical and health care...more

Foley & Lardner LLP

White Collar Enforcement and the New Trump Administration: Your Top Ten Questions Answered

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Enforcement activity under the Obama administration often made headlines for the eye-popping level of fines, with the Foreign Corrupt Practices Act (FCPA), Anti-Money Laundering (AML) regulations, and economic sanctions...more

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