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Friling Law

Voluntary Self-Disclosure to OFAC: Legal Framework and Strategic Considerations

Friling Law on

Lawyers regularly advise clients on navigating the complex and evolving U.S. sanctions regime enforced by the Office of Foreign Assets Control (“OFAC”). When a business or individual becomes aware of a potential violation of...more

Skadden, Arps, Slate, Meagher & Flom LLP

Annual Report Highlights France’s Financial Crime Enforcement and International Cooperation

Ten years after its establishment, France’s National Financial Prosecutor’s Office (Parquet National Financier or PNF) has released its 2024 annual report (Report),1 showcasing a year of consolidation and innovation in the...more

A&O Shearman

Poland post-regime change: shifting enforcement approaches to state-owned enterprises and their business partners

A&O Shearman on

There was significant legal and regulatory scrutiny across both private and state-owned sectors in Poland in 2024, focusing on business fraud, sanctions compliance, money laundering, and bribery. State-owned enterprises,...more

The Volkov Law Group

American Life Insurance Company Settles with OFAC for $178,421 Related to Apparent Violations of Iranian Transactions and...

The Volkov Law Group on

The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) recently settled with American Life Insurance Company (“ALICO”), a Delaware-based subsidiary of MetLife, Inc., for $178,421, addressing apparent...more

The Volkov Law Group

OFAC Imposes $860,000 Penalty on Vietnamese Beverage Company for Violations of North Korean Sanctions

The Volkov Law Group on

North Korea Sanctions Violations - In a recent enforcement action, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) imposed an $860,000 penalty on Vietnam Beverage Company Limited (“VBCL”), a...more

The Volkov Law Group

“The New FCPA”: The Future Landscape of Sanctions Enforcement (Part II of IV)

The Volkov Law Group on

We are all familiar with — over and over — third-party risks and FCPA risks. It is drilled in our collective heads — third-party risks and bribery. Legal and compliance professionals have to learn and understand the ins...more

The Volkov Law Group

DOJ, Commerce and Treasury Issue JCN on Foreign Person Liability for Sanctions and Export Controls Violations

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As DOJ, OFAC and BIS ramp up sanctions and export controls enforcement, they have continued to provide important compliance guidance.  You have to give the enforcement agencies credit — on the one hand, they regularly warn of...more

The Volkov Law Group

OFAC Settles First Case in 2024: EFG, a Private Bank, Pays $3.7 Million for Sanctions Violations

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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 Volkov Law Group

Preparing for the Storm — Effective Compliance in the New Sanctions Era (Part II of II)

The Volkov Law Group on

If companies operated with perfect governance mechanisms and controls, they would all be ready for the coming sanctions enforcement storm.  However, that is not the corporate reality.  Even after several companies are the...more

The Volkov Law Group

The Coming Corporate Sanctions Enforcement Storm (Part I of II)

The Volkov Law Group on

There are some things you learn best in calm, and some in storm.  Willa Cather I know I sound like a broken record.  The Justice Department’s white collar criminal enforcement  has been trending down over the last few...more

The Volkov Law Group

OFAC Begins to Roll Back Venezuelan Sanctions Relief, Again Prohibiting Transactions with CVG Minerven

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Easy come, easy go.  On January 29, 2024, OFAC published General License 43A under the Venezuela Sanctions Regulations, which partially rolled back a piece of the sanctions relief it provided to the country only a few months...more

The Volkov Law Group

2023 Sanctions Year in Review and Predictions

The Volkov Law Group on

As always, I tend to repeat myself.  However, one important point needs to be repeated — DOJ is in the midst of launching an aggressive sanctions and export control program against corporations and individuals.  DOJ has...more

The Volkov Law Group

OFAC Reaches Settlement with Cryptocurrency Company CoinList for Violations of Ukraine/Russia Sanctions

The Volkov Law Group on

On December 13, 2023, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) announced an enforcement action against CoinList Markets LLC (“CoinList”) for violations of the Ukraine-/Russia-Related...more

The Volkov Law Group

A pesar del alivio en materia de sanciones comerciales por parte del gobierno de EE.UU al sector del petróleo y gas en Venezuela...

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Control de Activos Extranjeros (“OFAC”) del Departamento del Tesoro de EE.UU. promulgó una serie de licencias generales al gobierno de Venezuela para brindarle un alivio al país de las sanciones económicas. La OFAC promulgó...more

The Volkov Law Group

Despite OFAC Sanctions Relief, the Venezuelan Oil and Gas Industry Still Presents Risks

The Volkov Law Group on

As we discussed previously, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) recently provided Venezuela with much needed sanctions relief.  Specifically, OFAC issued General License 44 (among...more

The Volkov Law Group

La Oficina de Control de Activos Extranjeros (OFAC) otorgó alivios a las sanciones comerciales en Venezuela y autorizó ciertas...

The Volkov Law Group on

El 18 de octubre de 2023, la Oficina de Control de Activos Extranjeros (“OFAC”) del Departamento del Tesoro de los Estados Unidos tomó varias medidas para proporcionar un alivio (limitado) de sus sanciones económicas en...more

The Volkov Law Group

OFAC Provides Venezuela with Sanctions Relief, Authorizes Certain Transactions in the Oil and Gas Industry

The Volkov Law Group on

On October 18, 2023, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) took several steps to provide Venezuela with some limited relief from its sanctions.  The relief includes General Licenses...more

The Volkov Law Group

Swedbank Latvia Settles with OFAC for $3.43 Million for Crimea Sanctions Violations

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OFAC continues its enforcement push.  At the same time, OFAC is managing a complex, global set of sanctions against Russia.  DOJ has promised to increase prosecution of global banks for sanctions violations....more

The Volkov Law Group

DOJ Flexes Enforcement Muscle to Target Viktor Vekselberg, a Russian Oligarch and Co-Conspirator Assisting in Evasion of Russia...

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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 Volkov Law Group

DOJ Charges Russian and British Businessmen for Facilitating Sanctions Evasion of Russian Oligarch’s $90 Million Yacht

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DOJ is poised for a big year in the enforcement of Russian Sanctions and seizure of assets connected to Russian Oligarchs.  It has been nearly a year since the U.S., its allies and partners have unleashed robust sanctions...more

The Volkov Law Group

Former Special Agent in Charge of the FBI New York Counterintelligence Division Charged with Violating Russia Sanctions

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In an ironic twist (or you just can’t make this up moment, whichever you prefer), the Justice Department announced the arrest of Charles McGonigal, the former Special Agent in Charge (“SAC”) of the FBI’s Counterintelligence...more

The Volkov Law Group

Navigating DOJ and OFAC Voluntary Disclosures for Sanctions Violations

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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

The Volkov Law Group

Sanctions Enforcement: “The New FCPA”

The Volkov Law Group on

Hold onto your hats – while we are on the cusp of more FCPA enforcement actions, the Justice Department and OFAC are gearing up for real and significant sanctions enforcement actions.  The dye is cast, so here we go. ...more

Torres Trade Law, PLLC

Trade Enforcement Digest - January 2022

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Civil and criminal penalties levied against U.S. companies for trade violations are just the beginning of the potential unforeseen costs of doing business in the global marketplace. What cannot be quantified are the countless...more

The Volkov Law Group

2022 OFAC and Sanctions Enforcement Predictions

The Volkov Law Group on

The Treasury Department’s Office of Foreign Asset Control (“OFAC”) has been a steady performer in this challenging pandemic environment.  Since the pandemic, OFAC has maintained a strong profile, while managing a difficult...more

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