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Office of Foreign Assets Control (OFAC) Foreign Corrupt Practices Act (FCPA)

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

Sanctions Compliance: Understanding the Red Lines of Enforcement (Part I of II)

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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

NAVEX

Sanctions are the “New” FCPA – How this Era of Enforcement Shapes Third-Party Risk Management

NAVEX on

In the summer of 2022, Deputy Attorney General Lisa Monaco – a veteran prosecutor and currently number two at the helm of the U.S. Department of Justice (DOJ) – began to describe the enforcement of sanctions regulations as...more

The Volkov Law Group

Episode 324 -- Third-Party Risks and Sanctions Compliance

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With the beginning of the “New FCPA” era coined by DOJ’s Deputy Attorney General Lisa Monaco, we now need to focus on third-party risk and sanctions enforcement. The law, the practice, and the risks are important and not just...more

The Volkov Law Group

The Same Old Song with a Different Meaning — Third-Party Risks and Sanctions Compliance (Part I of IV)

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Sorry to start a four-part series with a reference to music from our long-ago past.  The Four Tops sang the “Same Old Song, with a Different Meaning” (released in 1965). So, how does that relate to third-party risks?  Well,...more

King & Spalding

New Ten-Year Statute of Limitations for Sanctions Violations

King & Spalding on

Implications Related to the Doubling of the Statute of Limitations for Civil and Criminal Violations of Two Primary Sanctions Authorities - SUMMARY - On April 24, 2024, President Biden signed into law a foreign military...more

Womble Bond Dickinson

DOJ Enhancing Its Sanctions Toolkit

Womble Bond Dickinson on

President Biden recently signed a foreign aid bill that will have significant implications for United States sanctions enforcement, specifically Section 206 of the International Emergency Economic Powers Act (50 U.S.C. 1705)...more

Fenwick & West LLP

Sanctions Violations: New 10-Year Statute of Limitations

Fenwick & West LLP on

On April 24, 2024, President Biden signed into law an emergency supplemental appropriations law, H.R. 815 (Public Law 118-50), that provides substantial military aid to Ukraine, Israel, and Taiwan and could force the sale of...more

Lowenstein Sandler LLP

Trade Matters - Lowenstein Sandler's Global Trade & National Security Newsletter - April 2024

Ford Motor Company Agrees to $365M Settlement for Attempted Tariff Engineering Ford has agreed to settle the long-standing dispute over the tariff classification of vans imported from 2009 to 2013. At the time, Customs and...more

Adams and Reese LLP

International Compliance Digest – March 2024

Adams and Reese LLP on

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

Bass, Berry & Sims PLC

International Trade Enforcement Roundup – March 2024 Update

You are reading the March 2024 Update of the Bass, Berry & Sims Enforcement Roundup, where we bring notable enforcement actions, policy changes, interesting news articles, and a bit of our insight to your inbox. Overview...more

Bracewell LLP

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

Bracewell LLP on

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)

The Volkov Law Group on

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

Bass, Berry & Sims PLC

International Trade Enforcement Roundup – January 2024 Update

January saw continuing focus on Russia. First, the Commerce Department’s Bureau of Industry and Security (BIS) expanded export controls on certain goods for Russia and Belarus. Second, a U.S.-Israeli citizen was arrested for...more

The Volkov Law Group

Episode 307 -- Sanctions Enforcement Review and Predictions for 2024

The Volkov Law Group on

DOJ is in the midst of launching an aggressive sanctions and export control program against corporations and individuals.  DOJ has warned everyone, repeated this message in various speeches and, most importantly, assigned the...more

The Volkov Law Group

2023 Sanctions Year in Review and Predictions

The Volkov Law Group on

As always, I tend to repeat myself.  However, one important point needs to be repeated — DOJ is in the midst of launching an aggressive sanctions and export control program against corporations and individuals.  DOJ has...more

Bracewell LLP

“Export Controls Are the New Sanctions” and Other Enforcement Trends for 2024

Bracewell LLP on

2023 was a banner year in the sanctions space and regulators seem primed to continue that performance in 2024. In December 2023, numerous government officials and industry experts convened at the New York Forum on Economic...more

Bass, Berry & Sims PLC

International Trade Enforcement Roundup – December 2023 Update

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December saw continuing enforcement actions involving Russia. First, the Treasury Department’s Office of Foreign Assets Control (OFAC) settled investigations into apparent sanctions violations by a New York-based insurance...more

Akin Gump Strauss Hauer & Feld LLP

7 Enforcement Predictions For US Export Controls, Sanctions

Within the trade bar there is cautiousness, curiosity and skepticism at the numerous pronouncements signaling greater enforcement of export controls and sanctions by the Bureau of Industry and Security, the Office of Foreign...more

Bass, Berry & Sims PLC

International Trade Enforcement Roundup – November 2023 Update

Bass, Berry & Sims PLC on

You are reading the November 2023 Update of the Bass, Berry & Sims Enforcement Roundup, where we bring notable enforcement actions, policy changes, interesting news articles, and a bit of our insight to your inbox. ...more

Foley & Lardner LLP

International Trade, Enforcement & Compliance Recent Developments Update (October 25, 2023)

Foley & Lardner LLP on

A veritable grab bag of international trade developments to parse this week. Recent developments include increasing FCPA enforcement, a record OFAC economic sanctions penalty, and a large customs penalty for willful failure...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

Bass, Berry & Sims PLC

International Trade Enforcement Roundup – September 2023 Update

Bass, Berry & Sims PLC on

September saw a number of enforcement actions involving Iran. First, the Office of Foreign Assets Control (OFAC) announced separate settlements with 3M and Emigrant Bank for violations of the Iranian Transactions and...more

The Volkov Law Group

3M Pays OFAC $9.6 Million to Resolve Egregious Iran Sanctions Violations

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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

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