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
Episode 289 -- Justice, Commerce and Treasury Issue Joint Notice on Voluntary Disclosure
Evaluating Government Sanctions in the Payments Industry - Payments Pros: The Payments Law Podcast
FedNow Is Here! - Payments Pros: The Payments Law Podcast
Consumer Finance Monitor Podcast Episode: A Look at the Treasury Department’s April 2023 Report on Decentralized Finance or “DeFi”
Corruption, Crime, & Compliance - Cryptocurrency and Sanctions Compliance with Matt Stankiewicz
The Federal Reserve Bank of Philadelphia (the “Philly Fed”) recently executed an agreement (the “Agreement”) with Pennsylvania-based Customers Bank (and its Customers Bancorp, Inc. holding entity) (collectively, “Customers”)....more
New Tri-Seal Compliance Note highlights sanctions and export control compliance expectations for non-U.S. persons. Three agencies overseeing U.S. trade law compliance provided an overview of where U.S. sanctions and export...more
On March 14, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced its first enforcement case of the year and its first ever involving dealings with a Russian designated for sanctions...more
The United States manages more than three dozen separate economic and trade sanctions programs. Those programs target specified foreign governments along with thousands of named individuals, groups and entities in accordance...more
Those familiar with the U.S. import and export regulations know that U.S. Customs and Border Protection (“CBP” or “Customs”) generally enforces the U.S. import regulations, while multiple executive government agencies...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
Summary of What Has Happened and What Is Yet to Come - On 19 October 2023, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced a Notice of Proposed Rule Making (NPRM), pursuant to...more
Financial institutions and companies that are subject to oversight from the Office of Foreign Assets Control (OFAC) need to prioritize compliance. OFAC has become increasingly active in recent years, and it is devoting...more
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
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 United States Department of the Treasury has continued to signal that it will focus policy, regulatory, and enforcement attention on the financial crime and sanctions risk in the crypto and digital asset ecosystem...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
There is no question that ransomware is here to stay. Thirty-seven percent of the matters we handled last year involved ransomware, compared to 27 percent of matters in 2020. ...more
The uptick in recent sanctions activity caused in large part by the Russian Federation’s unprovoked and unilateral invasion of Ukraine has caused absolute pandemonium in many compliance circles. While the U.S. Department of...more
A well-known digital currency investment services company announced the launch of its first European exchange-traded fund (ETF), according to a press release this week. The ETF, which will be traded on multiple foreign...more
...Since the start of the invasion of Ukraine by Russian forces on February 24, the United States (U.S.), United Kingdom (UK), and the European Union (EU) have led a global sanctions campaign against Russia that has been...more
Entities facing significant legal risk, no matter the circumstances, if they make ransom payments to attackers connected to, or originating from Russia. As the Russian invasion of Ukraine continues, the U.S. government...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
The task of designing appropriate third-party sanctions controls requires reverse engineering of relevant caselaw, particularly, the Epsilon Electronics case, which I reviewed in Part I of this series, and the Department of...more
Welcome to the Financial Services Report, holiday style! Banks and non-banks alike started early this year with additions and changes to their regulator stockings. The Senate confirmed Rohit Chopra as the new CFPB Director....more
In October, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published new guidance for the virtual currency industry focusing on compliance with the financial industry’s obligations...more
On October 15, 2021, the US Department of the Treasury’s Office of Foreign Asset Control (OFAC) announced updated guidance for virtual currency companies in meeting their obligations under US sanctions laws. On the same day,...more
In keeping with the United States government’s expanding scrutiny of cryptocurrency markets, the DOJ recently announced the creation of a National Cryptocurrency Enforcement Team (the “NCET”). The NCET endeavors to add a...more
On October 15, 2021, the Office of Foreign Assets Control (OFAC) issued an advisory providing sanctions compliance guidance for the virtual currency industry (Guidance). The Guidance follows a series of recent enforcement...more
Guidance Demonstrates OFAC’s Expectations for Sanctions Compliance by Cryptocurrency Industry - On October 15, 2021, the Office of Foreign Assets Control (“OFAC”) of the U.S. Department of the Treasury published Sanctions...more