News & Analysis as of

Office of Foreign Assets Control (OFAC) Risk Assessment Compliance

Foley & Lardner LLP

What Every Multinational Company (Doing Business in Mexico) Should Know About … Mitigating Risks From ATA Scrutiny in a New...

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Mexican cartels dominate large swaths of the Mexico-United States border and the Bajío region (an area encompassing relevant parts of Queretaro, Guanajuato, Aguascalientes, San Luis Potosí, Jalisco, and Michoacán), and they...more

American Conference Institute (ACI)

[Event] 9th Annual Canadian Forum on Global Economic Sanctions - February 26th - 27th, Toronto, ON, Canada

CI’s 9th Annual Canadian Forum on Global Economic Sanctions is designed to cover your top compliance challenges, offering unparalleled networking and benchmarking opportunities for economic sanctions, trade, financial crime,...more

K2 Integrity

First Ever Targeted Guidance On Financial Institutions’ Compliance With Export Administration Regulations

K2 Integrity on

On 9 October 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) published its first ever unilateral guidance specifically addressed to financial institutions (FIs). The Guidance to Financial...more

Pillsbury Winthrop Shaw Pittman LLP

Non-U.S. Companies on Alert: U.S. Government Issues Tri-Seal Compliance Note on Global Enforcement

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

Seward & Kissel LLP

The Importance of Sanctions and Export Control Compliance

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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

Foley & Lardner LLP

What Every Multinational Company Should Know About . . . Implementing an International Compliance Program (Part I)

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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

Oberheiden P.C.

OFAC Compliance: Developing and Implementing an Effective Sanctions Compliance Program

Oberheiden P.C. on

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

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

The Volkov Law Group

Refreshing and Elevating Your Sanctions Compliance Program (Part II of III)

The Volkov Law Group on

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

Bracewell LLP

Check It Once, Check It Twice: OFAC Requests Daily Screenings of SDN List for Sanctions Compliance

Bracewell LLP on

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

The Volkov Law Group

Avoiding Compliance Overkill — Properly Assess and Manage Tangible Risks

The Volkov Law Group on

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

Guidepost Solutions LLC

Is Your Russia–Ukraine And Overall Sanctions Compliance Program Really Working? (Don’t Find Out the Hard Way)

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 Volkov Law Group

Assessing Third-Party Sanctions Risks (Part II of III)

The Volkov Law Group on

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

Faegre Drinker Biddle & Reath LLP

OFAC Issues Sanctions Compliance Guidance for Virtual Currencies

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

McDermott Will & Emery

OFAC Reaffirms Focus on Virtual Currency with Sanctions Law Guidance

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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

Fenwick & West LLP

Guidance for the Virtual Currency Industry; 2021 Sanctions Review Shows Increasing Focus on Digital Transactions

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On October 15, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued tailored sanctions compliance guidance for those operating in the virtual currency industry, including technology...more

Perkins Coie

OFAC Releases New Detailed Guidance for the Digital Currency Industry

Perkins Coie on

On October 15, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) released guidance on sanctions compliance for the digital currency industry, the agency’s most detailed guidance to date on...more

Society of Corporate Compliance and Ethics...

[Virtual Event] 2021 Middle East and Africa Regional Compliance & Ethics Conference - February 11th, 8:55 am - 2:00 pm GST

Our Virtual Regional Compliance Conferences provide updates on the latest news in regulatory requirements, compliance enforcement, and strategies to develop effective compliance programs. Watch, listen, and ask questions from...more

The Volkov Law Group

Five Basic Steps to Implement a Sanctions Compliance Program

The Volkov Law Group on

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

White & Case LLP

US Treasury Advises on Potential Sanctions Risks Raised by Ransomware Attacks

White & Case LLP on

On October 1, 2020, the US Department of the Treasury's Office of Foreign Assets Control ("OFAC") issued an advisory opinion on the sanctions risks associated with certain cyberattacks ("OFAC Guidance"). The OFAC Guidance...more

Morrison & Foerster LLP

Following U.S. Lead, UK Office Of Financial Sanctions Implementation Issues Maritime Guidance

Much of the world’s focus is on the COVID-19 pandemic, and rightfully so, but sanctions regulators also have their gazes fixed on another issue: the maritime industry. On May 14 2020, we saw the U.S. Departments of State and...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

NAVEX

Sanctions Compliance in the Era of Financial Warfare

NAVEX on

On May 1, 2019, the world of sanctions compliance was upended when the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) decided to jump into the compliance game by issuing its first-ever Framework for...more

Lowenstein Sandler LLP

U.S. Regulators Focus on Compliance Efforts in Enforcement Decisions Involving International Companies

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Over the past few years, U.S. regulators have made it clear that having comprehensive and effective compliance policies covering trade is a must, regardless of the company size, location or industry. The government’s move to...more

Society of Corporate Compliance and Ethics...

Focus on US economic sanctions compliance: OFAC imposes fines and expects more monitoring

Report on Supply Chain Compliance 3, no. 2 (January 23, 2020) - The U.S. Treasury Department’s Office of Foreign Assets Control (OFAC), the primary U.S. government agency that administers U.S. economic sanctions, was busy...more

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