Compliance Tip of the Day: COSO Governance Framework: Part 4, Culture
Compliance Tip of the Day: COSO Governance Framework: Part 2, Oversight
Compliance Tip of the Day: COSO Governance Framework: Part 1, Introduction
Compliance Tip of the Day: Design - Centric Internal Controls
Compliance Tip of the Day: Lessons from Internal Control Failures
Compliance Tip of the Day: Internal Control Deficiencies
Compliance Tip of the Day: Assessing Internal Controls
Compliance Tip of the Day: COSO Objective 5 – Monitoring Activities
Compliance Tip of the Day: COSO Objective 4 - Control Information and Communication
Compliance Tip of the Day: COSO Objective 3 – Control Activities
Compliance Tip of the Day – COSO Objective 1 – Control Environment
Compliance Tip of the Day: Code of Conduct as an Internal Control
Compliance Tip of the Day: COSO Framework
Compliance Tip of the Day: Internal Controls for GTE
Compliance Tip of the Day: Board Oversight on Internal Controls
Compliance Tip of the Day: Internal Controls for Third Parties
Compliance Tip of the Day: Implementing Internal Controls
Compliance Tip of the Day: Risk Assessments and Internal Controls
Compliance Tip of the Day: Issues for Internal Controls in International Operations
Compliance Tip of the Day: Top 4 Compliance Internal Controls
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
Avoiding Risk and Responding to It - You are cordially invited to a panel discussion with industry leaders from the energy sector, hosted by BakerHostetler's Energy, International Trade and International Arbitration and...more
With the current state of the world and heightened scrutiny of the nonprofit sector, it is critical that nongovernmental organizations (NGOs) with international reach routinely assess the effectiveness of their trade...more
We have received several requests for a list of the compliance policies that make sense for every multinational company. So, as a follow-up to our earlier two posts providing “twelve steps to international compliance” (see...more
In our prior update (published November 29), we provided the first five steps in our twelve-step program for international compliance. These steps are intended to help companies identify international regulatory risk inherent...more
Record penalties for violations of U.S. regulations governing international conduct and transactions illustrate the risk of costly enforcement actions facing multinational companies. Yet, many multinational companies lack...more
Is Your Compliance Program Designed for the Current Enforcement Landscape? Data protection, anti-corruption, antitrust, supply chains, economic sanctions and even the software employees use to communicate are all subjects...more
On March 16, 2003, the UK Financial Conduct Authority (FCA) published its letter Portfolio Letter: FCA priorities for payments firms to the CEOs of UK Payment Institutions (PIs), Electronic Money Institutions (EMIs), and...more
The U.S. Department of the Treasury's Office of Foreign Asset Control (OFAC) on Nov. 28, 2022, announced a more than $362,000 settlement with Payward Inc. d/b/a Kraken (Kraken), a Delaware-incorporated company that offers...more
Recent regulator statements and actions stress the need to empower compliance programs and officers and hold them accountable. As companies navigate the post-pandemic environment, legal and compliance teams should take...more
A recent OFAC enforcement action against MidFirst Bank highlights the five essential components of an effective sanctions compliance program that will serve to mitigate exposure in the event of a violation: Senior...more
Welcome to Banking Bites! This is our short summary flagging key developments in the UK that we hope will inform your activities in your market. This edition covers...more
ACI is excited to welcome you back in-person to the 14th Advanced Forum on FCPA & Anti-Corruption for the Life Sciences Industry, taking place on July 21–22, 2022 in Boston! Legal and compliance professionals from...more
You have to wonder how OFAC has the time to investigate and settle cases given its significant work implementing the Russia Sanctions Program. But OFAC continues to demonstrate its commitment to aggressive enforcement. ...more
On March 11, 2022, the UK Financial Conduct Authority (FCA), the Bank of England, and the Office of Financial Sanctions Implementation (OFSI) released a joint statement reiterating that all UK financial services firms,...more
How do you know if your sanctions compliance program (“SCP”) is really working? Can your firm really afford to find out the hard way – violations with major penalties, especially after regulators uncover your management did...more
OFAC is off to a quick start in 2022. After announcing its Airbnb enforcement action in the beginning of January, OFAC announced a settlement with Sojitz (Hong Kong) Limited, a Hong Kong, China-based company that engages in...more
On December 23, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) and TD Bank, N.A. (TD) reached a settlement to resolve TD’s violations of the North Korea Sanctions Regulations and the...more
On October 15, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued detailed guidance to the virtual currency industry, putting virtual currency companies on notice of the ways OFAC...more
In a new Sanctions Compliance Guide, The Office of Foreign Assets Control (OFAC) of the U.S. Treasury reiterates that compliance obligations apply equally to transactions involving virtual currencies and those involving...more
In response to the rapid growth of virtual currencies, the Treasury Department’s Office of Foreign Assets Control (“OFAC”) recently published Sanctions Compliance Guidance for the Virtual Currency Industry (“Guidance”)....more
Recently, the Financial Crimes Enforcement Network (FinCEN), a bureau of the U.S. Treasury Department, released a report on ransomware trends stating that during the first half of 2021, 68 different ransomware variants...more
This has been an interesting enforcement year. The Biden Administration promised a renewal of aggressive enforcement. The difficult transition from the last administration and political resistance to confirmation of...more
A ransomware attack is a major threat affecting all sectors of business, including healthcare. Organizations typically follow state and federal privacy laws as part of their ransomware prevention and response measures....more
Compliance teams looking to stay ahead of the changing landscape need to be up to date on the latest developments. Join us for Global Compliance Updates in collaboration with the DIFC Academy, on 2–3 November 2021. This...more