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
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
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
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
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
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
Economic sanctions have been increasingly used by countries and international organizations as a tool of foreign policy and national security. This increase in the use of sanctions, particularly by the U.S. Department of the...more
Despite a shift in the sanction landscape, it will take time for enforcement activity to catch up. As a result, organizations should regularly examine their exposure with business partners around the globe and consult with...more
Companies have to implement a sanctions compliance program (SCP). When I use the term SCP, I mean much more than just having one employee screen a customer before a shipment is sent. Too many companies are behind the 8-ball...more
Companies have had over one year to review and implement a sanctions compliance guidance program. This last year, however, has been difficult (to say the least) given the COVID-19 pandemic....more
On September 17, 2020, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) reached a $894,111 settlement with Comtech Telecommunications Corp. (“Comtech”) and its subsidiary Comtech EF Data Corp. (“EF...more
For international businesses, the costs of a weak sanctions compliance program can be steep, impacting both a company’s reputation and its bottom line. This year alone, the Treasury Department’s Office of Foreign Assets...more
OFAC (Oficina de Control de Activos Extranjeros) es un departamento del Tesoro de los Estados Unidos que administra y aplica sanciones económicas y comerciales basadas en la política exterior de los Estados Unidos y los...more
OFAC (Office of Foreign Assets Control) is a department of the US Treasury that administers and enforces economic and trade sanctions based on US foreign policy and national security goals. ...more
As companies elevate their “game” in sanctions compliance, it is important that compliance officers critically examine the strengths and weaknesses of their compliance programs. Many companies already have a screening...more
Based on its aggressive enforcement program and its recently issued Framework for Sanctions Compliance Programs, OFAC has established a new era in sanctions compliance. Trade compliance is often siloed into its own...more