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
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
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
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
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
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 U.S., EU and UK have imposed significant new sanctions and are stepping up enforcement against sanctions evaders on the second anniversary of Russia’s full-scale invasion of Ukraine. On February 23, 2024, the U.S....more
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
Over the last several months, companies have become entangled in an increasingly complex web of new and expanded sanctions and export control restrictions related to Russia in response to its war on Ukraine. The current...more
Construction Specialties, Inc. (“CSI”), a U.S. company specializing in the sale of building materials, agreed to pay $660,594 to settle its liability for three violations of OFAC’s sanctions on Iran. CSI’s illegal conduct...more
In another significant step notifying global businesses of the new realities – companies are about to face aggressive coordinated criminal and civil prosecutions for sanctions and export control violations. The last piece in...more
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
On April 25, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced a $508 million settlement with one of the world’s largest tobacco companies to resolve potential civil liabilities stemming from...more
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
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
OFAC closed out 2022 with a late-night $4.3 million settlement with Danfoss A/S, a Danish manufacturer of refrigeration and cooling products for violations of the Iran, Syria and Sudan sanctions programs. OFAC has had a...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
The Office of Foreign Assets Control (“OFAC”) has demonstrated its ability to multi-task — designing, implementing and enforcing a comprehensive sanctions regime against Russia after its invasion of Ukraine, and maintaining...more
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
Facing the myriad third-party sanctions risks can be daunting. Many global organizations rely on a network of third-party intermediaries that pose a variety of risks. To mitigate those risks, companies have to implement...more
If there is one issue that is repeated over and over (and over), it is third-party risks. Over the last ten years, we have witnessed an explosion in anti-corruption enforcement around the world. And with this enforcement...more
Mashreqbank, based in Dubai, agreed to pay $100 million to the New York Department of Financial Services, the Federal Reserve, and the Office of Foreign Asset Control for violation of the now-repealed Sudan Sanctions...more
PT Bukit Muria Jaya (BMJ), a global supplier of cigarette paper based in Indonesia, agreed to pay $1,561,570 for conspiracy to commit bank fraud as part of a scheme to deceive various banks in order to collect payments for...more
In the new Biden Administration, companies should expect aggressive enforcement of trade sanctions. At the same time, in response to Russian aggression and the Solar Winds cyber-attack, OFAC is likely to implement new and...more
OFAC reported two new enforcement actions in the week between Christmas and New Year’s. The two new enforcement actions are interesting examples of sanctions enforcement, one of which involved the first against a digital...more