Managing Sanctions Compliance
Regulatory Ramblings: Episode 68 - Why Geopolitical Risk Matters to Compliance and Legal Staff with Mark Nuttal and Chad Olsen
FCPA Compliance Report: Amanda Carty on a Due Diligence and Risk Management
Episode 364 -- Five Strategies to Mitigate a New Risk Environment
Strengthening Compliance: Lessons From the OCC's Consent Order With Patriot Bank — Payments Pros – The Payments Law Podcast
Compliance and AI: Ali Khan on Implementing AI Risk Management Systems
Compliance Tip of the Day: Superforecasting
Compliance Tip of the Day: The Last Mile
Key Takeaways From the OIG's New Compliance Guidance for Nursing Facilities — Assisted Living and the Law Podcast
Envisioning a Compliant Workforce
Updating the Research Compliance Handbook
The Election's Impact on the FTC Will Bring Big Changes, But Being Vigilant Must Remain a Priority
Navigating the NYDFS' Cybersecurity Guidance on AI — The Consumer Finance Podcast
The Future of AI Regulation and Legislation: 5 Key Takeaways
Investigations and Cognitive Interviews
Fraud Prevention Techniques for Nonprofit Organizations - Part 3
Steps Your Nonprofit Can Take to Mitigate Fraud Risks - Part 2
A Third Party's Perspective on Third Party Risk
Implications of the SEC Cybersecurity Disclosure Rule
Privacy Issues from Third-Party Website Tags
It’s not a good time to be a manufacturer of ten-foot poles. That’s because with the growing number of sanctions regimes, there are an increasing number of companies and individuals that businesses shouldn’t touch with a poll...more
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
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
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
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
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
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
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
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 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
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
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
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
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
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
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
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
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
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
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
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