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 20, 2025, President Trump issued an executive order titled “Designating Cartels and Other Organizations as Foreign Terrorist Organizations and Specially Designated Global Terrorists.” This directive instructs the...more
OFAC means what it says — in more ways than one. In a precedent setting case, OFAC brought its first enforcement action against an individual for violating the Global Magnitsky Sanctions Regulations....more
Key Points - - Political transitions in the West notwithstanding, we expect economic sanctions to remain a key response to geopolitical issues. - Current sanctions policy priorities are unlikely to shift markedly in...more
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
Compliance with sanctions regimes has been a priority for debt markets. Amid rising geopolitical tensions, the stakes for lenders and borrowers are higher than ever - Intensifying geopolitical tensions and the US...more
You are reading the March 2024 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. Overview...more
The sanctions world experienced another action-packed year in 2023. Sanctions against Russia dominated the year in terms of the number of designations and new restrictions, and the attacks perpetrated by Hamas in Israel on 7...more
On December 13, 2023, CoinList Markets LLC (“CoinList”) agreed to pay $1,207,830 pursuant to a settlement agreement with the Office of Foreign Assets Controls (“OFAC”) in connection with allegations that the San Francisco...more
With so many new, emerging risks coming to the forefront, ACI is excited to announce our Digital Assets Compliance: AML, Sanctions and Regulatory Oversight. Unlike other conferences, this highly anticipated event stands apart...more
On August 16, 2023, OFAC announced a $660,594 settlement with Construction Specialties Inc. (CS) for alleged violations of the Iranian Transactions and Sanctions Regulations (ITSR). OFAC found that CS’s wholly controlled...more
The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), on August 8, 2022, sanctioned virtual currency mixer Tornado Cash. OFAC alleged that it had been “used to launder more than $7 billion worth of...more
The Treasury Department’s Office of Foreign Assets Control (OFAC) took action last Monday, November 8, 2021, and sanctioned a Latvia-based exchange, Chatex, its associated support network, and two ransomware operators for...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
The Biden Administration this quarter announced fewer targeted sanctions, but issued several “whole of government” advisories regarding sanctions risks associated with China-related business dealings, as well as virtual...more
In a keynote address at the Global Investigations Review Connect: New York conference on October 5, Principal Associate Deputy Attorney General John Carlin provided insights into future Department of Justice (“DOJ” or the...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
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 September 21, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued an updated advisory outlining the risks involved with facilitating ransom payments to malicious actors conducting...more
LIVE and IN-PERSON ACI’s Flagship Conference in December! ACI’s 15th Flagship Conference on U.S. Economic Sanctions Enforcement and Compliance is North America’s largest and most comprehensive conference on economic...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
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 29, 2021, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”), the agency that enforces and administers U.S. economic and trade sanctions, announced a settlement with Dallas-based MoneyGram...more
As virtual assets explode in value, use, and popularity, governments around the world are taking notice, increasing sanctions-related scrutiny of companies that provide related services and focusing regulatory and enforcement...more
On February 18, 2021, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) entered into a settlement of $507,375 with BitPay, Inc. (BitPay) for violations of multiple U.S. sanctions programs. According to...more
As we previously wrote in our OFAC 2020 Year in Review, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) saw a drop in enforcement activity in 2020, likely due to the massive year it had in 2019 and...more