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Office of Foreign Assets Control (OFAC) Whistleblowers

Adams and Reese LLP

International Compliance Digest – August 2024

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August was another robust month in international trade that further signifies the need for corporations to invest in effective compliance programs. For starters, the DOJ unveiled a new program that incentivizes corporate...more

BakerHostetler

Weekly Blockchain Blog - August 2024 #3

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Crypto Firms Announce New Products in Payments, Investments, Custody - A major U.S. digital asset management company recently announced the creation and public launch of its MakerDAO Trust, which “offers investors the...more

The Volkov Law Group

DOJ and OFAC Sanctions and Export Control Detection Strategies

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In this new aggressive era of sanctions and export controls enforcement, companies need to understand the potential risks that DOJ and/or OFAC may identify a company for sanctions investigation....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

Bracewell LLP

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

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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

Morrison & Foerster LLP

U.S. Sanctions Enforcement: 2023 Trends and Lessons Learned

Today’s alert—the second in our Sanctions 2023 Year in Review Series—provides an overview of U.S. sanctions enforcement in 2023, including the key lessons learned from the public enforcement actions issued by the U.S....more

Bracewell LLP

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

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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

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

Foodman CPAs & Advisors

Nota De Cumplimiento Del BIS, DOJ Y OFAC

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El 26/07/2023, el Departamento de Justicia de los EE. UU. (DOJ), la Oficina de Industria y Seguridad del Departamento de Comercio de los EE. UU. (BIS) y la Oficina de Control de Activos Extranjeros (OFAC) del Departamento del...more

Foodman CPAs & Advisors

Compliance Note From BIS, DOJ & OFAC

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On 07/26/2023, the U.S. Department of Justice (DOJ), the U.S. Department of Commerce’s Bureau of Industry and Security (BIS), and the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), issued a...more

Ballard Spahr LLP

New FinCEN Director Addresses Key Topics in BSA/AML

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The new Director of FinCEN, Andrea Gacki, addressed several key topics on October 3, 2023 at the Association of Certified Anti-Money Laundering Specialists (“ACAMS”) conference in Las Vegas, Nevada. Specifically, Director...more

Skadden, Arps, Slate, Meagher & Flom LLP

OFAC Enforcement Action Emphasizes the Importance of Whistleblower Programs

On August 16, 2023, OFAC announced a $660,594 settlement with Construction Specialties Inc. (CS) for alleged violations of the Iranian Transactions and Sanctions Regulations (ITSR). OFAC found that CS’s wholly controlled...more

Jones Day

Federal Agencies Highlight Benefits of Self-Disclosure, Emphasize Enforcement of Trade Violations in Tri-Seal Compliance Note

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In a coordinated announcement, federal agencies stress the benefits of voluntarily disclosing potential trade violations while emphasizing increased enforcement....more

Husch Blackwell LLP

The Government Continues to Prioritize Export Control and Sanctions Enforcement Highlighted in New Tri-Seal Compliance Note and...

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On Wednesday, July 26, the Departments of Commerce, Treasury, and Justice issued a Tri Seal Compliance Note detailing the voluntary self-disclosure of potential violations for export controls, sanctions, and other national...more

K2 Integrity

DOJ, BIS, and OFAC Issue Tri-Seal Compliance Note Consolidating Information Regarding Voluntary Self-Disclosure Policies

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The U.S. Department of Justice (DOJ), the U.S. Department of Commerce’s Bureau of Industry and Security (BIS), and the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) published their second Tri-Seal...more

Paul Hastings LLP

DOJ OFAC BIS Joint Compliance Note and Enhanced Coordination Highlights Increased Enforcement Risk

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On July 26, 2023, the U.S. Departments of Justice, Treasury, and Commerce issued a joint compliance note (“JCN”) regarding voluntary self-disclosure (“VSD”) policies that apply to potential violations of U.S. sanctions...more

Ballard Spahr LLP

“Tri-Seal” Compliance Notice: U.S. Authorities Release Joint Guidance on Voluntary Self-Disclosure of Potential Sanctions and...

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On July 26, the Department of Commerce, the Department of the Treasury, and the Department of Justice released a joint compliance notice (the “Compliance Notice”) updating and summarizing each agency’s position regarding the...more

Venable LLP

Honesty is Good for Your Bottom Line: Commerce, Treasury, and DOJ Tout the Benefits of Voluntary Self Disclosure in Tri-Seal...

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Voluntary self-disclosure is a valuable remediation measure for companies who identify their own potential violations of U.S. sanctions, export controls, and other national security laws....more

Skadden, Arps, Slate, Meagher & Flom LLP

US Authorities Hammer Home the Importance of Self-Disclosing Sanctions and Export Control Violations

On July 26, 2023, the U.S. Department of Justice’s (DOJ’s) National Security Division (NSD), the U.S. Department of Commerce’s Bureau of Industry and Security (BIS), and the U.S. Department of the Treasury’s Office of Foreign...more

Fenwick & West LLP

New Official Guidance on Voluntary Self-Disclosure of Trade Control Violations

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On July 26, 2023, the U.S. Department of Commerce, Bureau of Industry and Security (BIS), the U.S. Department of the Treasury Office of Foreign Asset Control (OFAC) and the U.S. Department of Justice (DOJ) released joint...more

Wiley Rein LLP

A New Era of Export Control and Sanctions Enforcement

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Since the Russian invasion of Ukraine in February 2022, the U.S. government has made it increasingly clear that enforcement of export control and economic sanctions laws is a top priority. From launching task forces to target...more

Torres Trade Law, PLLC

New Anti-Money Laundering Whistleblower Law Makes Economic Sanctions Violations Reportable

To more effectively counter transnational corruption and economic sanctions evasion, recent changes to the U.S. anti-money laundering (“AML”) whistleblower regime expand and reinforce whistleblower protections and rewards in...more

King & Spalding

New BSA/AML Regime Promises Sweeping Changes

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As we wrote over the summer, Congress has passed a bill that will require certain corporations and limited liability companies (“LLCs”) to report information on their beneficial owners to the U.S. Treasury Department’s...more

Ballard Spahr LLP

Would-Be Whistleblower Fails to Show Causation Under the Bank Secrecy Act for Termination

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The Southern District of New York (“SDNY”) recently rejected a retaliation claim brought by a former bank employee under the Bank Secrecy Act (“BSA”), granting summary judgment in favor of the employer bank because the former...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - April 2020

ANTICORRUPTION DEVELOPMENTS - New Guilty Plea in College Admissions Scandal - On April 21, 2020, Jorge Salcedo, a former tennis coach at a prominent California university, entered into a plea agreement related to his...more

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