Key Discovery Points: If You Dispose of Relevant Hard Drives You Will Face (Some) Consequences
eDiscovery Case Law Podcast: How Failing to Meet and Confer Effectively Can Lead to Sanctions
Episode 339: Four Sanctions Cases Everyone Should Know
Corruption, Crime and Compliance - “The New FCPA”: Sanctions and Export Control Enforcement and Compliance
Giving Compliance Advice
Corruption, Crime, & Compliance - Five Steps to Enhance Your Sanctions Compliance Program
Corruption, Crime and Compliance - Deep Dive Into Wells Fargo’s $30 Million OFAC Settlement
FINCast Ep. 36 – Regulators’ Roundtable to Forecast 2023
Guidepost in Motion EP25: State of Compliance with Alixandra Smith Part 2
FCPA Compliance Report - Matt Silverman on Potential Sanctions Against Russia
Argentina: A Look at the Case of Lázaro Báez - Laundering the Proceeds of Corruption and Tax Fraud
Nota Bene Podcast Episode 131: U.S. Sanctions Against Russia: Valid or Ineffective Economic Policy? with Fatema Merchant and Mario Torrico
Compliance into the Weeds - SAP Trade Sanctions Enforcement Action
What to Expect from the Biden Administration
A Look Ahead at the Biden Administration’s Regulatory and Enforcement Priorities
Compliance Perspectives: The German Corporate Sanctions Act
Episode 153 -- The Mighty Amazon Falls to OFAC Enforcement Sword
Navigating an Increasingly Complex Sanctions Landscape: New Exposures for Corporations and Shipping
Episode 120: Interview of NAVEX Global Third-Party Risk Officials: Chris Bailey and Stephen Gooding
U.S. policy reversal allows suits in U.S. courts and visa denials, for “trafficking” in confiscated property in Cuba
On January 3, 2025, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced sanctions on a Chinese-based cybersecurity company, Integrity Technology Group, Inc. (“Integrity Tech”). These sanctions...more
Closing the year with a renewed focus on the People’s Republic of China, the Biden Administration imposed new export restrictions on US-origin technology to Chinese tech firms to hinder the PRC’s military and security...more
On September 21, 2021, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) published an updated sanctions advisory, providing guidance to companies on sanctions compliance obligations related to ransomware...more
Federal officials have recently warned employers and businesses that they could have insult added to injury if they respond to cyberattacks by making ransomware payments – increasingly requested through cryptocurrency – as...more
On October 18, 2021, the U.S. Department of the Treasury released the results of its broad review of economic and financial sanctions. The review, initiated by the Biden administration, included discussions with Congress,...more
On September 21, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced several actions focused on disrupting criminal digital finance infrastructure, including virtual currency...more
In the wake of increased ransomware attacks over the course of the last several months, the US Department of Treasury’s Office of Foreign Assets Control (OFAC) has updated a guidance it released last year on potential...more
The US Department of the Treasury’s Office of Foreign Assets Control (OFAC) recently issued an “Updated Advisory on Potential Sanctions Risks for Facilitating Ransomware Payments.” This advisory continues prior advisory...more
Ransomware payments continue to be a focus of the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”). As previously reported by Foley Hoag, on October 1, 2020, OFAC released an advisory regarding potential...more
Many companies have a “no ransomware payment” stance until faced with a ransomware attack, especially an attack that causes significant business disruption. At that point, the company may reconsider its stance (or at least...more
Recently, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) sanctioned various individuals and entities connected to Russia’s technology sector and also expanded sanctions against dealings in Russian...more
On April 15, 2021, the Biden Administration took a number of steps to sanction Russia for its role in cyberattacks, election interference, and other malign activities the U.S. government attributed to Moscow. These actions...more
On April 15, 2021, President Biden signed a new executive order, Blocking Property with Respect to Specified Harmful Foreign Activities of the Government of the Russian Federation, escalating US sanctions against the Russian...more
Both the Office of Foreign Assets Control (OFAC) and the Financial Crimes Enforcement Network (FinCEN) of the U.S. Department of Treasury have issued advisories recently regarding regulatory considerations financial...more
On October 1, 2020, the U.S. Treasury's Office of Foreign Assets Control (OFAC) issued a new advisory spotlighting sanctions risks for companies that facilitate ransomware payments, including financial institutions, cyber...more
On October 1, 2020, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) released an advisory regarding potential sanctions risks related to facilitating ransomware payments... OFAC is the federal...more
On Thursday, October 1, 2020, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued an advisory highlighting potential sanctions risks associated with ransomware payments related to malicious...more
Ransomware attacks – cyber attacks in which the hackers encrypt and disable an organization’s computers and demand a ransom to provide the decryption key – continue to hit organizations throughout the country. Perhaps even...more
Anticorruption Developments - The U.S. Court of Appeals for the 10th Circuit Rules That the SEC's Use of ALJs is Unconstitutional - On December 27, 2016, the U.S. Court of Appeals for the 10th Circuit ruled 2-1...more
President Obama amended a previously-issued executive order designed to address cyber-enabled activities yesterday in response to “Russia's cyber activities [that] were intended to influence the election, erode faith in U.S....more
The United Nations Security Council (“UNSC”) approved a Resolution last week imposing new sanctions against North Korea in response to its recent nuclear and missile tests. This UNSC action follows the enactment of the North...more
The Department of Treasury’s Office of Foreign Asset Control continues to ramp up sanctions enforcement. Even with the likely relaxation of the Iran and Cuba sanctions, OFAC has been continuing its aggressive enforcement...more
Five Lessons Health Care Companies Should Learn From Cyberattacks - The American health care industry is under attack by sophisticated hackers seeking access to electronic medical records. Since January, three health...more
President Obama recently issued Executive Order 13694 (EO 13694 or EO), “Blocking the Property of Certain Persons Engaging in Significant Malicious Cyber-Enabled Activities.” EO 13694 is aimed at deterring cyber attacks,...more
On April 1, 2015, President Barack Obama issued an executive order (the Order) authorizing sanctions against foreign individuals or entities found to be responsible for certain malicious cyberattacks. Under the Order, the...more