Daily Compliance News: July 21, 2025, The More Reasons Not to Go to China Edition
All Things Investigation: Due Diligence and Drama: A Deep Dive into Art World with Daniel Weiner
Compliance Tip of the Day: Lessons from Internal Control Failures
Daily Compliance News: July 7, 2025 the Disaster on the River Edition
10 For 10: Top Compliance Stories For the Week Ending June 28, 2025
The Dark Patterns Behind Corporate Scandals
Compliance into the Weeds: Boeing’s New Safety Initiatives and Compliance Reforms
10 For 10: Top Compliance Stories For the Week Ending June 21, 2025
Daily Compliance News: June 13, 2025. The All Boeing Edition
Adventures in Compliance: The Novels: The Sign of Four – Applying Sherlock Holmes’ Methods to Modern Corporate Compliance
2 Gurus Talk Compliance: Episode 53 – The AI as a Whistleblower Edition
Great Women in Compliance: From Hotline to Headline: The DOJ’s Whistleblower Awards Reboot with Mary Inman and Liz Soltan
Compliance into the Weeds: Autonomous AI Whistleblowing Misconduct
Compliance into the Weeds: Boeing, a NPA and the End of Monitors
Daily Compliance News: May 16, 2025, The Ethics Nightmare Edition
Compliance into the Weeds: USRA Declination Case Study - Self-Disclosure Best Practices
Daily Compliance News: April 28, 2025, The Santos Sobs Edition
Compliance into the Weeds: The Uncertain Future of Compliance Monitors under the Trump Administration
Podcast - Looking into the Crystal Ball: The Future of Consumer Protection Law Enforcement
2 Gurus Talk Compliance: Episode 49 - The Depression Episode
On June 16, 2024, the U.S. Department of Justice’s (DOJ) National Security Division (NSD) and the U.S. Attorney’s Office for the Southern District of Texas (SDTX) announced the first-ever declination to prosecute a firm and...more
The Financial Crimes Enforcement Network (FinCEN) is one of a handful of federal authorities that have adopted whistleblower programs focused on facilitating enforcement in hard-to-target areas. While FinCEN focuses its...more
Family International, a Florida real estate company, and its U.S. owner, Roman Sinyavsky, settled with OFAC for $1.07 million for 73 violations of the Russia Sanctions program. In a separate criminal case, Roman Sinyavsky...more
Saves Lives, Prevents Major Crimes, and Accelerates Voluntary Self - Disclosures The U.S. Department of Justice (“DoJ”) recently spotlighted its Whistleblower Awards Program and Voluntary Self Disclosure (“VSDs”)...more
Companies and their executives can reduce Department of Justice (DoJ), OFAC, and Commerce Department risks (and liability) by understanding and respecting the relationship between economic sanctions, voluntary...more
On July 26, 2023, the departments of Commerce, Justice and the Treasury issued their second ever to date “Tri-Seal Compliance Note” (the “Note”). It describes expectations for the voluntary disclosure of sanctions, export,...more
United States international trade regulatory agencies have updated voluntary self-disclosure (“VSD”) policies and guidance in an effort to incentivize private sector companies and individuals to self-report violations of U.S....more
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
Key Points - On March 30, 2023, OFAC announced a settlement agreement with Wells Fargo for 124 apparent violations of three different sanctions programs (Iran, Syria and Sudan), all related to a legacy Wachovia Bank...more
Microsoft’s remedial steps provide important best-practices for companies facing similar risk factors in the global economy, especially for global software companies that rely on Internet-based operations....more
Not that I am a glutton for punishment, but I always find enforcement actions to supply a number of valuable lessons learned. There are always instructive nuggets of information, opportunities missed, and root causes that...more
In our lifetime (however long or short), there is no way any company will ever match Wells Fargo for its record of misconduct, criminal and civil enforcement, and regulatory fines and penalties. No one, no way....more
The Department of Justice is pushing its commitment to voluntary disclosure programs. Companies, however, are not lining up at DOJ’s door. The balance between sitting tight or voluntary disclosures requires care....more
Addressing the Evolving Risks - Warren Buffett said that “only when the tide goes out do you discover who’s been swimming naked.” Buffett was not talking about compliance programs in a time of crisis, but his wisdom applies...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
2019 has been a very significant year for every compliance practitioner and compliance program. There were three significant releases of information by the federal government which directly impacted compliance professionals...more
• On December 13, 2019, the Department of Justice (DOJ) revised and re-issued its “Export Controls and Sanctions Policy for Business Organizations” (the “Revised Policy”) to “provide greater clarity for companies faced with a...more
Last week, British Arab Commercial Bank (BACB), located in the United Kingdom, agreed to settle an OFAC enforcement action for $4 million. ...more
As the third in a triumvirate of releases on compliance programs, the Department of Justice (DOJ) Antitrust Division, in July the released its Evaluation of Corporate Compliance Programs in Criminal Antitrust Investigations...more
OFAC is clearly sending a message about sanctions enforcement and compliance responsibilities. OFAC is aggressively seeking out new targets for enforcement. OFAC continues to focus on Iran, Cuba, Venezuela and North Korea,...more
Bob Dylan, Watch the River FlowI have to admit it – I still love to listen to Bob Dylan. With age, his lyrics resonate more and more. HERE is a nice version of Watch the River Flow in case you want to listen while reading...more
Earlier this month, the U.S. Department of Justice (“DOJ”) and the U.S. Department of the Treasury’s Office of Foreign Asset Controls (“OFAC”) both issued guidance regarding their expectations for corporate compliance...more
OFAC’s new Framework for Sanctions Compliance Programs incorporates a number of important principles from Justice Department and US Sentencing Guideline requirements for effective compliance programs. ...more
ANTICORRUPTION DEVELOPMENTS - Deputy Attorney General Rod Rosenstein Announces Pursuing Individuals Will be a “Top Priority” for Corporate Enforcement Actions - On November 29, 2018, Deputy Attorney General Rod J....more
ANTICORRUPTION DEVELOPMENTS - DOJ Extends FCPA Corporate Enforcement Policy to Misconduct in Mergers and Acquisitions - On July 25, 2018, in a speech to the Ninth Global Forum on Anti-Corruption Compliance in High Risk...more