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
As the interplay between export controls, trade sanctions, and anticorruption enforcement continues to intensify, multinational companies must remain vigilant in ensuring that their compliance programs address the many...more
The U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) has released updated guidance concerning recent legislation that doubled the statute of limitations for violations of certain sanctions and export control...more
On April 24, 2024, President Biden signed into law H.R. 815 (Pub. L. 118-50), “Making emergency supplemental appropriations for the fiscal year ending September 30, 2024, and for other purposes” (the “Act”), which includes...more
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
In this new era of aggressive sanctions enforcement, companies have to understand the red lines that define where criminal and civil enforcement risk increase. In contrast to the history of FCPA enforcement, DOJ and OFAC...more
Key Points - On May 21, 2024, the DOJ announced its first ever declination under the NSD’s updated Enforcement Policy, declining to prosecute Sigma-Aldrich Inc., d/b/a MilliporeSigma (a subsidiary of Merck KGaA, Darmstadt,...more
On 24 April 2024, President Biden signed into law H.R. 815, “Making Emergency Supplemental Appropriations for the Fiscal Year Ending September 30, 2024, and for Other Purposes” (the Act). The long-awaited piece of legislation...more
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
April was another month of robust trade actions aimed at foreign goods, export compliance, and heightened enforcement powers. DHS issued an enhanced strategy policy on the textile industry with a focus on de minimis...more
The measure also harmonizes Russia sanctions rules with allies, and intensifies penalties against Iran - The National Security Act, 2024 (Pub. L No 118-50) was enacted on April 24, 2024. In addition to the Act’s provisions...more
As DOJ, OFAC and BIS ramp up sanctions and export controls enforcement, they have continued to provide important compliance guidance. You have to give the enforcement agencies credit — on the one hand, they regularly warn of...more
Hosted by the C5 Group Inc., the 2024 European Forum on Global Economic Sanctions will explore the evolution of the global economic sanctions landscape, analyzing everything from the shifting geopolitics around the globe, to...more
On March 7, 2024, the US Department of Justice’s National Security Division (NSD) released a revised Voluntary Self-Disclosure (VSD) Policy (the “VSD Policy”). The VSD Policy substantially tracks the language of the previous...more
On FINCast Episode 39, Juan Zarate sits down with K2 Integrity’s Katya Hazard and Amir Fadavi to discuss the state of Russia-related sanctions and to explore what has worked and what may require further coordinated efforts to...more
The U.S. Government recently announced the largest round of sanctions against the Russian Federation (Russia) since the invasion of Ukraine two years ago. This multi-agency effort enacted over 500 sanctions against foreign...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
On 22 December 2023, the Biden administration issued Executive Order 14114, “Taking Additional Steps with Respect to the Russian Federation’s Harmful Activities” (EO 14114), thereby amending EOs 14024 and 14068. The new EO...more
Immerse yourself in the only comprehensive economic sanctions event of its kind in Canada, spanning two days of invaluable insights and practical knowledge. Designed to cover U.S., EU, and major global sanctions, this...more
ACI’s highly anticipated Proficiency Series on Economic Sanctions provides true immersion into Economic Sanctions with the objective of becoming proficient in 4 weeks. Advance your career and professional development by...more
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
You are reading the November 2023 Update of the Bass, Berry & Sims Enforcement Roundup, where we bring notable enforcement actions, policy changes, interesting news articles, and a bit of our insight to your inbox. ...more
As we have repeatedly noted in the context of other blog posts and webinars in which various representatives of The Volkov Law Group have participated, the violation of existing U.S. sanctions and export control regulations...more
On 6 November 2023, the Department of the Treasury’s Financial Crimes Enforcement Network and the Department of Commerce’s Bureau of Industry and Security issued a joint notice concerning a new Suspicious Activity Report key...more
Over the last several months, companies have become entangled in an increasingly complex web of new and expanded sanctions and export control restrictions related to Russia in response to its war on Ukraine. The current...more
Each year, the Office of Foreign Assets Control (OFAC) initiates several enforcement actions targeting companies, financial institutions, and individuals in the United States and abroad. These enforcement actions can present...more