Navigating 2025: Trends in OFAC and DOJ Enforcement for Digital Assets — The Crypto Exchange Podcast
Virtual Currency Regulations: Key Insights for the Payments Industry — Payments Pros – The Payments Law Podcast
The Presumption of Innocence Podcast: Episode 54 - The Flaws of FARA: Feeble Oversight of Billions in Foreign Influence
Episode 352 -- Review of 2024 DOJ and SEC Sanctions Enforcement and Compliance
Unpacking the Fifth Circuit's Landmark Tornado Cash Decision — The Crypto Exchange Podcast
The Justice Insiders Podcast - The Ever-Expanding Net: Corporate Compliance in an Era of Increasing Trade Sanctions and Restrictions
Episode 328 -- Sanctions Enforcement Risks and Redlines
Corruption, Crime and Compliance: Third-Party Risks and Sanctions Compliance
Episode 324 -- Third-Party Risks and Sanctions Compliance
Will Resiliency Carry the Digital Asset Sector Through 2024: Federal Legislative Developments and OFAC Consent Orders — The Crypto Exchange Podcast
Corruption, Crime & Compliance: Deep Dive into SCG Plastics’ $20 Million Settlement with OFAC to Resolve Violations of Iran Sanctions Program
Episode 319 -- Deep Dive into SCG Plastics' $20 Million Settlement with OFAC for Violations of the Iran Sanctions Program
Wiley's 10 Key Trade Developments: Evolution of Export Controls
Wiley’s Top 10 Trade Developments: Heightened Sanctions and Export Control Enforcement
Corruption, Crime and Compliance: Trade Compliance Trends and Expectations with Gabrielle Griffith
Episode 308 -- Gabrielle Griffith, Director BPE Global, on Trade Compliance
Corruption, Crime and Compliance: DOJ and OFAC Sanctions Enforcement Review for 2023
Episode 307 -- Sanctions Enforcement Review and Predictions for 2024
Episode 302 -- Matt Stankiewicz on DOJ's Massive Criminal Settlement with Cryptocurrency Exchange Binance and its CEO Changpeng Zhao
Episode 294 -- Catch Up on OFAC Enforcement: 3M and Emigrant Bank
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
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
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
The U.S. Department of the Treasury's Office of Foreign Asset Control (OFAC) on Nov. 28, 2022, announced a more than $362,000 settlement with Payward Inc. d/b/a Kraken (Kraken), a Delaware-incorporated company that offers...more
A recent OFAC enforcement action against MidFirst Bank highlights the five essential components of an effective sanctions compliance program that will serve to mitigate exposure in the event of a violation: Senior...more
ACI is excited to welcome you back in-person to the 14th Advanced Forum on FCPA & Anti-Corruption for the Life Sciences Industry, taking place on July 21–22, 2022 in Boston! Legal and compliance professionals from...more
You have to wonder how OFAC has the time to investigate and settle cases given its significant work implementing the Russia Sanctions Program. But OFAC continues to demonstrate its commitment to aggressive enforcement. ...more
How do you know if your sanctions compliance program (“SCP”) is really working? Can your firm really afford to find out the hard way – violations with major penalties, especially after regulators uncover your management did...more
OFAC is off to a quick start in 2022. After announcing its Airbnb enforcement action in the beginning of January, OFAC announced a settlement with Sojitz (Hong Kong) Limited, a Hong Kong, China-based company that engages in...more
On October 15, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued detailed guidance to the virtual currency industry, putting virtual currency companies on notice of the ways OFAC...more
On Oct. 15, 2021, the Treasury Department’s Office of Foreign Assets Control (OFAC) published sanctions compliance guidance for the virtual currency industry. OFAC acknowledged that virtual currencies are playing an...more
This has been an interesting enforcement year. The Biden Administration promised a renewal of aggressive enforcement. The difficult transition from the last administration and political resistance to confirmation of...more
On June 3 of this year, the Biden Administration made plain its commitment to fighting corruption around the world, releasing a document identifying the fight against corruption “as an economic and national security priority”...more
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
Companies have to implement a sanctions compliance program (SCP). When I use the term SCP, I mean much more than just having one employee screen a customer before a shipment is sent. Too many companies are behind the 8-ball...more
Companies have had over one year to review and implement a sanctions compliance guidance program. This last year, however, has been difficult (to say the least) given the COVID-19 pandemic....more
After a short visit to Val Lewton’s Cat People, I return to conclude this multipart series on the Framework for OFAC Compliance Commitments (Framework). Every compliance professional of any stripe needs to read, understand...more
I am in a multipart series on the Framework for OFAC Compliance Commitments (Framework). Every compliance professional of any stripe needs to read, understand and implement some of the key concepts of the Framework into your...more
As the third in a triumvirate of releases on compliance programs, the Department of Justice (DOJ) Antitrust Division, released its Evaluation of Corporate Compliance Programs in Criminal Antitrust Investigations(Antitrust...more
As companies elevate their “game” in sanctions compliance, it is important that compliance officers critically examine the strengths and weaknesses of their compliance programs. Many companies already have a screening...more
Based on its aggressive enforcement program and its recently issued Framework for Sanctions Compliance Programs, OFAC has established a new era in sanctions compliance. Trade compliance is often siloed into its own...more
When providing compliance program guidance, the Justice Department and OFAC, like every compliance practitioner, will pay homage to the relatively obvious point that there is no one-size-fits-all compliance solution. ...more
The term “internal controls” is a loaded one – it morphs in various ways depending on the context. Sometimes it is a shorthand for financial accounting controls; other times it encompasses a company’s compliance controls...more
OFAC’s new framework guidance for sanctions compliance programs stretched into new territory with its risk assessment requirement. This new approach reflects OFAC’s recent aggressive enforcement programs....more
If you follow my blog, you know I am not one to embrace hyperbole. So, forgive me for stretching a little here, but the OFAC Framework for Sanctions Compliance Programs is a game changer. Let me explain why I am saying...more