Compliance into the Weeds: Sanctions Compliance Failures: Lessons from Harman International and Interactive Brokers
The Presumption of Innocence Podcast: Episode 66 - Tariff Uncertainty and Compliance Risks for Businesses
FCPA Compliance Report: The Impact of Secondary Tariffs on Global Trade with Mike Huneke and Brent Carlson
Regulatory Ramblings: Episode 73 - Geopolitical Risk: Thai Tensions / Sanctions, Tariffs & FCPA Enforcement in Asia
Episode 376 -- DOJ's Unicat Settlement and the Future Look of Trade Enforcement Actions
2 Gurus Talk Compliance – Episode 54 – The FCPA is Back On Edition
10 For 10: Top Compliance Stories For the Week Ending June 14, 2025
Daily Compliance News: June 9, 2025, The Repugnant Edition
Daily Compliance News: May 29, 2025, The 0 – 3 Edition
Compliance in the Former Soviet Central Asian Republics
Managing Sanctions Compliance
Innovation in Compliance: Navigating Regulatory Changes and Compliance in Trade and Data Privacy with Stephanie Font
All Things Investigations: Task Force Strategies - Addressing New Government Priorities
Payments Medley: Navigating Trends in Payments With Jason Mikula - Payments Pros – The Payments Law Podcast
Episode 365 -- Four Sanctions Cases Everyone Should Know
Compliance Tip of the Day: Essential Economic Data for Navigating Tariffs
Daily Compliance News: April 14, 2025, The Cascade of Corruption Edition
Episode 364 -- Five Strategies to Mitigate a New Risk Environment
Sunday Book Review: April 13, 2025, The Books on Trade and Tariffs Edition
Daily Compliance News: April 11, 2025 The Tariff Rollback Edition
The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced a historic $215,988,868 civil monetary penalty against GVA Capital Ltd. (GVA), a venture-capital firm registered in the Cayman Islands...more
On June 12, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) imposed a civil penalty of approximately $216 million on GVA Capital Ltd., a venture capital firm based in San Francisco, for...more
Córdoba Music Group LLC (Córdoba), a manufacturer of musical instruments based in California, has agreed to pay $41,591 to settle its civil liability for violations of sanctions on Iran. On nine occasions, Córdoba shipped...more
C.H. Robinson International Inc. (CHR), a Minnesota-based global transportation and logistics company, has agreed to pay $257,690 to settle civil liability for 82 apparent violations of sanctions against Iran and Cuba...more
In late August 2024, the UK’s Office of Financial Sanctions Implementation (“OFSI”), a department within HM Treasury, imposed a monetary penalty of £15,000 on Integral Concierge Services Limited (“ICSL”)—a UK-based property...more
The United States manages more than three dozen separate economic and trade sanctions programs. Those programs target specified foreign governments along with thousands of named individuals, groups and entities in accordance...more
Within the trade bar there is cautiousness, curiosity and skepticism at the numerous pronouncements signaling greater enforcement of export controls and sanctions by the Bureau of Industry and Security, the Office of Foreign...more
On November 21, 2023, the U.S. Office of Foreign Assets Control (OFAC) announced its largest settlement in history with the virtual currency exchange Binance. This almost-billion dollar settlement is a part of a larger...more
Rewards programs have become ubiquitous in recent years. These so-called loyalty management programs exist to nudge customers or employees in a particular direction; a company’s workers might be inclined to exercise more...more
Each year, the Office of Foreign Assets Control (OFAC) initiates several enforcement actions targeting companies, financial institutions, and individuals in the United States and abroad. These enforcement actions can present...more
Shipping companies should remain focused on sanctions compliance for 2023. The sanctions space has been bursting with activity as a result of the Russia-Ukraine war, which shows no signs of abating. Companies continue to seek...more
ANTICORRUPTION DEVELOPMENTS - New Guilty Plea in College Admissions Scandal - On April 21, 2020, Jorge Salcedo, a former tennis coach at a prominent California university, entered into a plea agreement related to his...more
• Actions underscore long arm of U.S. sanctions jurisdiction • Voluntary disclosures and cooperation can lead to significant penalty reductions • Facilitation of a violation is treated the same as a direct violation ...more
IN THIS ISSUE • Anticorruption Developments • Export Control Sanctions and Customs Enforcement • Export Control and Sanctions Developments • Global Investigations Resources • Writing and Speaking Engagements ...more
Report on Supply Chain Compliance 3, no. 4 (February 20, 2020) - The United States lifted sanctions[1] on a subsidiary of COSCO Shipping Corporation Ltd., the Chinese shipping giant. Last September, the U.S. Department of...more
On New Year’s Eve, a federal court relieved ExxonMobil of a $2 million fine levied against the company by the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”). OFAC imposed the penalty against Exxon for...more
OFAC investigations are often triggered as a result of: • Reports that are generated by U.S. Financial Institutions which have blocked or rejected a transaction based on a suspected sanctions violation • A self-disclosure...more
Report on Supply Chain Compliance 3, no. 2 (January 23, 2020) - The U.S. Treasury Department’s Office of Foreign Assets Control (OFAC), the primary U.S. government agency that administers U.S. economic sanctions, was busy...more
• $2 million penalty against Exxon overturned • Court concluded that OFAC failed to provide clear notice of violative conduct • Companies are at risk when acting in context of ambiguous agency guidance At the end of...more
Apollo Settles Alleged Sanctions Violations: Aircraft Lessors Pay Attention - The Office of Foreign Assets Control (OFAC) of the U.S. Department of the Treasury has broad delegated authority to administer and enforce the...more
The Office of Foreign Assets Control (OFAC) of the U.S. Department of the Treasury has broad delegated authority to administer and enforce the sanctions laws and related sanctions programs of the United States. As a key...more
Report on Supply Chain Compliance 2, no. 23 (December 12, 2019) - The United States Department of the Treasury’s Office for Foreign Asset Control (OFAC) reached a settlement with Apple, Inc. for “apparent violations of the...more
Report on Supply Chain Compliance 2, no. 20 (Oct. 24, 2019) - The U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) reached a settlement with General Electric Company regarding transactions involving a...more
In yesterday’s posting, I examined the General Factors identified by OFAC to determine whether to initiate a civil penalty proceeding and the amount of any civil monetary penalty. After analyzing these factors, OFAC...more
The Situation: Using a novel approach, the U.S. Department of the Treasury's Office of Foreign Assets Control ("OFAC") concurrently designated a non-U.S. individual to the Foreign Sanctions Evaders ("FSE") List in connection...more