Episode 324 -- Third-Party Risks and Sanctions Compliance
FINCast Ep. 39 – State of Russia Sanctions Two Years After the Invasion
Understanding the Additional Risks When Making a Ransomware Payment
Looking The Other Way: Recent Cases Of AML And Sanctions Failings In Scandinavia
Episode 118 -- Update on OFAC Enforcement and Lessons Learned
We all know what a “core” sanctions violation looks like. The heartland of such misconduct has been described on numerous occasions in OFAC enforcement actions and settlements. In this environment, however, companies have...more
With the beginning of the “New FCPA” era coined by DOJ’s Deputy Attorney General Lisa Monaco, we now need to focus on third-party risk and sanctions enforcement. The law, the practice, and the risks are important and not just...more
On 19 May, Directive (EU) 2024/1226 on the definition of criminal offences and sanctions for breaches of EU restrictive measures, adopted by the EU Council on 24 April, entered into force. By harmonizing the laws of the...more
On 24 April 2024, the EU adopted a new directive (Directive (EU) 2024/1226 of the European Parliament and of the Council) which establishes EU-wide rules for defining criminal offences and penalties related to the violation...more
On 24 April 2024, the European Union adopted a directive criminalizing the following sanctions violations: The directive brings significant changes to EU sanctions enforcement by harmonising the rules on the violation of EU...more
July saw two noteworthy Russia enforcement actions. A Russian national was arrested in Estonia and extradited to the United States after being charged with conspiring to procure U.S.-origin technologies and ammunition on...more
Company executives and stakeholders in charge of making decisions to insulate their business from legal liability by the Office of Foreign Assets Control (OFAC) at the U.S. Department of Treasury have a difficult choice to...more
The Justice Department warned companies that sanctions enforcement is the “new FCPA.” DOJ just delivered its first salvo to back up its message....more
I am sticking with my 2023 prediction – DOJ is committed to aggressive enforcement of the Russia sanctions. Most of its efforts to date have been directed against Russian Oligarchs and significant evaders who are moving...more
With a ninth sanctions package against Russia in the making, the EU’s sustained response to the war in Ukraine has demonstrated that sanctions will remain at the forefront of EU policymaking. The array of sanctions adopted...more
The U.S. Attorney’s Office for the Southern Direct of New York recently announced the indictment of Jack Hanick, a United States citizen, of violating the U.S. sanctions against Russia and false statements in connection with...more
Mashreqbank, based in Dubai, agreed to pay $100 million to the New York Department of Financial Services, the Federal Reserve, and the Office of Foreign Asset Control for violation of the now-repealed Sudan Sanctions...more
The long political and prosecution standoff between the U.S. Government/Department of Justice and Huawei/China ended abruptly last week when Wanzhou Meng, CFO of Huawei Technologies Co., Ltd. appeared in federal district...more
Attorney General William P. Barr Announces Publication of Cryptocurrency Enforcement Framework - "The Framework provides a comprehensive overview of the emerging threats and enforcement challenges associated with the...more
Report on Supply Chain Compliance 3, no. 10 (May 14, 2020) - The U.S. government charged two men with conspiring to launder money into the United States in order to purchase a Greek-owned ship to transport petroleum out...more
In 2019, the Department of Treasury’s Office of Foreign Asset Control (OFAC) issued important guidance on sanctions compliance programs. OFAC’s guidance sets out new and prescriptive requirements for sanctions compliance...more
On December 13, 2019, the Department of Justice (DOJ) updated its enforcement guidelines to include a no-fine, no-prosecution presumption for companies that voluntarily self-disclose potentially willful violations of the...more
IN THIS ISSUE • Anticorruption Developments • Export Control Sanctions and Customs Enforcement • Export Control and Sanctions Developments • Global Investigations Resources • Writing and Speaking Engagements ...more
U.S. Developments - U.S. Regulatory Developments - Bill Addressing Tax Treatment of Crypto Transactions Introduced to the House - On January 16, 2020, Congresswoman Suzan DelBene (WA) and Congressman David Schweikert...more
In the fourth quarter of 2019, U.S. enforcement authorities sustained efforts to prosecute individuals violating U.S. anticorruption laws in matters related to Latin America, while authorities in Latin America, including in...more
Court Rejects Attempt by Halkbank to Enter “Special Appearance” Contesting Jurisdiction - Turkish state-owned bank Halkbank’s efforts to avoid appearing in U.S. federal court for arraignment were squashed recently in a...more
• On December 13, 2019, the Department of Justice (DOJ) revised and re-issued its “Export Controls and Sanctions Policy for Business Organizations” (the “Revised Policy”) to “provide greater clarity for companies faced with a...more
Report on Supply Chain Compliance 2, no. 22 (November 21, 2019) - Behzad Pourghannad, an Iranian citizen, was sentenced to 46 months in prison for illegally importing carbon fiber from the United States into Iran from 2008...more
The Justice Department and the Treasury Department’s Office of Foreign Asset Control (OFAC) are on a roll. Global banks are facing renewed prosecutions, along with aggressive sanctions prosecutions of companies for...more
ANTICORRUPTION DEVELOPMENTS - DOJ Unseals Indictment of Two More Individuals Connected With PDVSA Corruption Scheme - On February 26, 2019, the U.S. Department of Justice (DOJ) announced the unsealing of an indictment...more