The Justice Insiders Podcast - The Ever-Expanding Net: Corporate Compliance in an Era of Increasing Trade Sanctions and Restrictions
Understanding the Additional Risks When Making a Ransomware Payment
WorldSmart: The Extraordinary Sanctions Against Russia - What Happens Next?
BSA, OFAC, KYC, and CIP – What do they mean to me? [More with McGlinchey, Ep. 29]
Compliance Perspectives: Sanctions, Data and Vetting Third Parties
FINCast Ep. 19 - The DPRK Sanctions Program
Episode 118 -- Update on OFAC Enforcement and Lessons Learned
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
OFAC is getting ready for a big year. While managing a comprehensive set of sanctions against the Russian Federation in response to its Invasion of Ukraine, OFAC has demonstrated its ability to maintain aggressive...more
The various and elusive tactics used by Russia to evade global sanctions and export controls have grown increasingly sophisticated over the last several months, putting the onus on multinational entities to become equally...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
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
The Treasury Department’s Offices of Foreign Assets Control (“OFAC”) continues its enforcement run in 2021, and added yet another tech company to its list of targets....more
On June 3 of this year, the Biden Administration made plain its commitment to fighting corruption around the world, releasing a document identifying the fight against corruption “as an economic and national security priority”...more
Deutsche Bank continues to have its problems – legal, compliance and reputational. Now, we can add OFAC sanctions compliance to the list of Deutsche Bank’s troubles....more
OFAC continues to aggressively enforce its sanctions programs. In its latest enforcement action, OFAC agreed with Société Internationale de Télécommunications Aéronautiques SCRL (“SITA”), a Swiss telecom company, to an...more
OFAC had a big year in 2019 and 2020 looks like a continuation. In the last week, OFAC issued two enforcement actions — Eagle Shipping and Park Strategies....more
This is the sixth in our start-of-year series examining important trends in white collar law and investigations in the coming year. Our previous entry discussed enforcement by the Massachusetts Attorney General’s Office in...more
Apollo Aviation Group, now Carlyle Aviation Partners, agreed to pay OFAC $210,600 for 12 violations of the Sudanese Sanctions Program. Carlyle acquired Apollo in December 2018, and Carlyle was not involved in the...more
OFAC's aggressive enforcement program continues. Recently, OFAC announced settlements with Apollo Aviation and Apple. Both of these cases underscore the importance of enhancing OFAC compliance programs. In this Episode,...more
OFAC’s aggressive enforcement program continues to bear fruit. The latest settlement involved GE and three of its subsidiaries, which agreed to pay $2.7 million for 289 alleged violations of the Cuba Sanctions Program. So...more
On June 21, 2019, OFAC changed its requirements for reporting on blocked or rejected transactions under 31 C.F.R. §501.604. With little fanfare, the interim rule published in the Federal Register greatly expands the...more
There is no question that OFAC continues to dominate the enforcement landscape this year. OFAC has provided plenty of warning and notice to global companies, especially those in the manufacturing and industrial sectors....more
SEA View: Our new monthly periodical has launched! From April 2019, this periodical will feature investigation, compliance, and regulatory developments in Southeast Asia (SEA). For a twelve-month spell, one monthly article...more
The Department of Treasury’s Office of Foreign Asset Control (“OFAC”) recently announced a settlement against Cobham Holdings (and its former subsidiary Aeroflex/Metelics, Inc. (“Metelics”, a software company) for $87,507 for...more
The Trump Administration Treasury Department’s Office of Foreign Asset Control activity has been interesting to watch. On the one hand, OFAC has been implementing aggressive sanctions against Russia in reaction to Russia’s...more
In this era of aggressive enforcement, global companies have to integrate beneficial ownership requirements when conducting due diligence of business associates and when engaging customers....more