Navigating U.S.-China Relations: Lessons From History for Today’s Global Economy
Regulatory Ramblings: Episode 68 - Why Geopolitical Risk Matters to Compliance and Legal Staff with Mark Nuttal and Chad Olsen
All Things Investigations: Terrorism Designations of Mexican Cartels Fundamentally Enhances Risk for All Companies
The Presumption of Innocence Podcast: Episode 54 - The Flaws of FARA: Feeble Oversight of Billions in Foreign Influence
Leaders in Law: The State of International Trade with Neena Shenai
Ambassador Jim Gilmore: From the Popular Virginia Car Tax Reimbursements to Current Foreign Affairs
Wiley's 10 Key Trade Developments: Evolution of Export Controls
Video: Making Trade Inclusive for All Americans: A Conversation with SAP's Michelle Trong Perrin-Steinberg
Hot Topics in International Trade
The New Cold War: Risk, Sanctions, Compliance Episode 22: "Focus on Iran: Protests, Sanctions and Oil"
Freedom Fund: Looking Towards a Financial NATO
The Justice Insiders: Why Russia Sanctions Matter – Even if You’re Not an Oligarch
The Impact of War on Commercial Contracts and the Global Supply Chain
FINCast Ep. 33 - Russian Invasion of Ukraine: The Role of Sanctions and the Rupture of the International Order
WorldSmart: Arent Fox and Its Sovereign Representation in the International Marketplace
What to Expect from the Biden Administration
What Will the U.S. Election Mean for Canada?
ITAR for Facility Security Officers
Compliance Perspectives: NDAA 889, Better Known as the Anti-Huawei Act
FINCast Ep. 19 - The DPRK Sanctions Program
As the new administration shifts some criminal enforcement priorities, particularly relating to activities abroad, potential targets of cross-border investigations are re-evaluating their strategies and exposure to...more
The much-heralded end to prosecutions brought pursuant to the Foreign Corrupt Practices Act (FCPA) never materialized during the first Donald Trump administration, but Trump 2.0 has the potential to bring major change to the...more
Since its enactment in 1977, the FCPA has been the primary legal mechanism in the United States for preventing and punishing corrupt business practices around the world. At a high-level, the FCPA applies to both domestic and...more
On February 5, 2025, on her first day in office, U.S. Attorney General Pam Bondi issued fourteen memos outlining new policies for the U.S. Department of Justice (“DOJ”) in a broad range of enforcement arenas. Among these Day...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
What happened? On September 10, the SEC announced that John Deere agreed to pay almost $10 million to resolve allegations it had violated the FCPA. The SEC alleged that Wirtgen Thailand, an indirect subsidiary of John Deere,...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
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 past few weeks have not been kind to 3M. The company recently settled with the SEC for $6.5 million to resolve alleged FCPA violations related to its Chinese subsidiary’s dealings with Chinese state-owned healthcare...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
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
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
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
In May 2019, OFAC released its Framework for a Sanctions Compliance Program. OFAC announced that it intended to increase the prosecution of individuals for sanctions violations. OFAC has brought two cases against...more
The Treasury Department’s Offices of Foreign Assets Control (“OFAC”) continues its enforcement run in 2021, and added yet another tech company to its list of targets....more
The Treasury Department’s Office of Foreign Asset Control (OFAC)continues to pile up sanctions enforcement actions. As the Biden Administration slowly takes over the reins of the Department of Treasury, OFAC enforcement is...more
The path, once again, is clear: regulators look favorably upon organizations that flag compliance issues for internal investigations, self-report violations, and cooperate with government officials. This strategy was...more
OFAC continues to chalk up enforcement actions. For the year, even with the pandemic slow down, OFAC has reached 13 settlement agreements totaling $18.6 million in penalties....more
When you are hot, you are hot. (And when you are not, you are not; Thank you Jerry Reed, Country Singer). OFAC is hot and resumed its enforcement streak, settling three enforcement actions in three weeks....more
Apollo Aviation Group, now Carlyle Aviation Partners, agreed to pay OFAC $210,600 for 12 violations of the Sudanese Sanctions Program. Carlyle acquired Apollo in December 2018, and Carlyle was not involved in the...more
The City of London has denied Uber’s request to extend its license in the city over concerns for rider safety. The decision puts Uber’s 45,000 drivers there in limbo, though they’ll be able to continue operating while the...more
There is no question that OFAC continues to dominate the enforcement landscape this year. OFAC has provided plenty of warning and notice to global companies, especially those in the manufacturing and industrial sectors....more
Global banks are the poster children of sanctions violations and the importance of trade compliance. At the top of the heap is Standard Chartered Bank....more