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
North Korean IT operatives are infiltrating U.S. and Western companies using stolen or fabricated identities, VPNs, and U.S.-based co-conspirators to gain unauthorized access to corporate systems. These insider threats pose...more
New bribery offenses in Australia now make it easier for authorities to prosecute organizations and require companies to exercise greater oversight and controls. Australia’s regulators remain active in greenwashing and other...more
NIS2 (Network and Information Systems Directive 2) is the updated version of the NIS Directive, which the EU first introduced in 2016. The original NIS Directive aimed to enhance cybersecurity across member states by...more
In an era marked by heightened global regulatory scrutiny and enforcement, the landscape of risk and compliance is undergoing an evolution making the strategic imperative for effective, risk-based compliance initiatives...more
Many HIPAA covered entities and business associates struggle with developing and implementing a sanctions policy. What should it say, is zero-tolerance required, do we have to impose discipline in every case, etc. These are...more
Recent enforcement actions highlight the increased regulatory scrutiny that private funds may face with respect to internal cybersecurity protocols and responses to cyber-crimes and cyber incidents under new and updated...more
Join American Conference Institute at the 7th Annual Legal, Regulatory and Compliance Forum on FinTech & Emerging Payment Systems on April 18-19, 2023, in New York! Gain key insights into the hurdles arising amid...more
On July 7, 2022, three federal agencies – the Federal Bureau of Investigation, the Cybersecurity and Infrastructure Security Agency, and the Department of the Treasury – issued a joint alert regarding Maui Ransomware, which...more
1. Treasury Mandates Reporting of Foreign Securities Holdings of $200M or More- All U.S. persons (custodians and end investors) who manage $200 million or more in foreign securities for themselves or others must file a...more
1. New Cybersecurity Export Controls From BIS Go Into Effect in January - The Bureau of Industry and Security (BIS) has released an interim final rule establishing new export controls on certain cybersecurity items and...more
Guidance Demonstrates OFAC’s Expectations for Sanctions Compliance by Cryptocurrency Industry - On October 15, 2021, the Office of Foreign Assets Control (“OFAC”) of the U.S. Department of the Treasury published Sanctions...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
On 21 September 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued an updated advisory that highlights the sanctions risks associated with making ransomware payments. OFAC reiterated...more
On Tuesday, the U.S. Department of Treasury’s Office of Foreign Asset Control (“OFAC”) issued an updated advisory warning all ransomware victims that if they succumb to ransomware demands and pay foreign actors who are...more
In This Issue. The U.S. Securities and Exchange Commission (SEC) published a sample comment letter on climate change disclosures; the Financial Industry Regulatory Authority (FINRA) is conducting a review of brokerage firm...more
On September 21, 2021, the Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions on SUEX OTC, S.R.O, a cryptocurrency exchange, for its role in laundering money to ransomware attackers. According...more
1. Recent Enforcement: Even Companies That Invest in Compliance Pay Penalties- Since our April enforcement roundup, the Office of Foreign Assets Control (OFAC) and the Bureau of Industry and Security (BIS) in the Department...more
On April 15, 2021, following discussions just days earlier of a potential summit between President Biden and Russian President Putin and as Russian troops amassed along the Ukrainian border, the Biden Administration issued...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
Companies that make or facilitate ransomware payments were given a strong reminder of their due-diligence and compliance obligations by the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”). ...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
As businesses continue to digitise their assets and operations, the need to continually assess IT infrastructure and the technical measures in place to safeguard key information assets and data becomes ever more important....more