Corporate Governance, Internal Controls, Office of Foreign Assets Control (OFAC)

The Non-Compliant Cat in the Hat

Foley & Lardner LLP on 4/18/2025

So, just before Easter, in 1957, a little book you may have heard of, called The Cat in the Hat, made its first appearance. Theodore Geisel — writing under the name “Dr. Suess” — later said that of all his children’s books,...more

Refreshing and Elevating Your Sanctions Compliance Program (Part II of III)

The Volkov Law Group on 5/17/2023

Let’s move beyond the headline – trade compliance is the new FCPA. We get it. The next step is to do something about it. The Justice Department has repeated this refrain – it is one of its greatest hits. In addition, DOJ,...more

Gatekeeper Misfires and Corporate Governance Failures

The Volkov Law Group on 12/3/2020

Here is another obvious point – internal controls are intended to ensure compliance with relevant policies and procedures. Internal controls are not just for show, or not just limited to financial reporting. A compliance...more

The OFAC Compliance Framework: Element 4 & 5 – Testing and Auditing & Training

Thomas Fox - Compliance Evangelist on 10/14/2019

After a short visit to Val Lewton’s Cat People, I return to conclude this multipart series on the Framework for OFAC Compliance Commitments (Framework). Every compliance professional of any stripe needs to read, understand...more

OFAC Issues Sanctions Guidance and the Concept of Culture Gains Traction

Dorsey & Whitney LLP on 5/17/2019

On May 2, 2019, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”)—the U.S. agency tasked with administering and enforcing the U.S.’s economic and trade sanctions programs—published A Framework for...more

Recent guidance brings OFAC in line with domestic and global compliance trends

Eversheds Sutherland (US) LLP on 5/15/2019

On May 2, 2019, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued guidance titled “A Framework for OFAC Compliance Commitments” (Guidance), providing direction regarding what OFAC considers to...more