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
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
On July 15, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced a settlement agreement with Interactive Brokers LLC (“Interactive Brokers”) violations of multiple U.S. sanctions...more
DOJ’s Unicat resolution is a perfect example of the new trade enforcement reality under the Trump Administration. DOJ spearheaded a global resolution of sanctions, customs and export controls violations, while declining to...more
The Treasury Department’s Office of Foreign Asset Control (“OFAC”) has been relatively quiet on the enforcement front. That is not unusual — every transition results in an enforcement hiatus. Sanctions enforcement is a...more
In a May 12, 2025, memorandum (the May Memorandum) on focus, fairness and efficiency in the fight against white collar crime, the Department of Justice (DOJ) Criminal Division1 again identified the total elimination of...more
Since the mid-1990s, the Executive Branch has sought to target foreign terrorist organizations, and those individuals and organizations supporting them, in order to degrade their funding and support. Organizations and...more
The recent sentencing of Israeli freight forwarder Gal Haimovich to two years in federal prison for violations of U.S. export controls serves as a striking example of the aggressive enforcement posture adopted by U.S....more
On February 5, 2025, President Trump's nominee to lead the Justice Department (the "Department"), Pamela Bondi, was confirmed by the Senate to serve as the U.S. Attorney General. Bondi immediately took action to reshape the...more
On February 5, 2025, the newly sworn-in United States Attorney General, Pamela Bondi, issued 14 memos to DOJ employees. The memos make clear that, under AG Bondi, DOJ’s enforcement efforts will focus on (i) immigration...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
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
Enforcement and compliance prognosticators (like myself) continued to push DOJ’s promise to transform sanctions enforcement into the era of “the new FCPA.” While DOJ’s promise to bring about an aggressive corporate...more
Key Points - - Political transitions in the West notwithstanding, we expect economic sanctions to remain a key response to geopolitical issues. - Current sanctions policy priorities are unlikely to shift markedly in...more
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
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
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
Checklists can be handy — by simplifying and focusing on specific issues, a checklist can organize thinking and prioritize tasks. Here are five (5) questions that are fairly simple but revealing as to whether a company’s...more
Sorry to start a four-part series with a reference to music from our long-ago past. The Four Tops sang the “Same Old Song, with a Different Meaning” (released in 1965). So, how does that relate to third-party risks? Well,...more
This is the tenth in our 2024 Year in Preview series examining important trends in white collar law and investigations in the coming year. Our previous post, "Health Care Fraud Enforcement in 2024," can be found here....more
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
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
Following the invasion of Ukraine by Russia on February 24, 2022, the United States ("US"), the European Union ("EU"), and the United Kingdom ("UK") adopted—together with their allies—successive waves of sanctions, in an...more
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
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