News & Analysis as of

Internal Controls SDN List

Stankie Law

Important Sanctions Compliance Lessons from OFAC’s $11.8m Settlement with Interactive Brokers

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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

Foley & Lardner LLP

What Every Multinational Company Should Know About . . . Implementing an International Compliance Program (Part II)

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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

Foley & Lardner LLP

What Every Multinational Company Should Know About . . . Implementing an International Compliance Program (Part I)

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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

Bracewell LLP

Check It Once, Check It Twice: OFAC Requests Daily Screenings of SDN List for Sanctions Compliance

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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

The Volkov Law Group

Global Logistics Company Settles OFAC Violations for $6.1 Million

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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

Skadden, Arps, Slate, Meagher & Flom LLP

US Treasury Provides Detailed Guidance for the Virtual Currency Industry on Sanctions Compliance

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

Foodman CPAs & Advisors

OFAC Puts Virtual Currency Industry on Notice

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

Herbert Smith Freehills Kramer

OFAC Issues Sanctions Compliance Guidance for Virtual Currency Industry

On Oct. 15, 2021, the Treasury Department’s Office of Foreign Assets Control (OFAC) published sanctions compliance guidance for the virtual currency industry. OFAC acknowledged that virtual currencies are playing an...more

Nossaman LLP

How to Prevent an OFAC Sanction When Responding to a Ransomware Attack

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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

Womble Bond Dickinson

Administration's Anti-Corruption Efforts Likely to Yield Greater FCPA Enforcement in Latin America and Beyond

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On June 3 of this year, the Biden Administration made plain its commitment to fighting corruption around the world, releasing a document identifying the fight against corruption “as an economic and national security priority”...more

Foodman CPAs & Advisors

El Programa de Cumplimiento de Sanciones de la OFAC le aplica a todos

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

Foodman CPAs & Advisors

The OFAC Sanctions Compliance Program applies to all

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

Bass, Berry & Sims PLC

OFAC Actions Provide Guidance on Sanctions Compliance Best Practices

• Russian corporations de-listed through significant specific steps agreed to with OFAC • Exporter settles for $7.7 million and agrees to comprehensive compliance measures • OFAC outlines sanctions compliance best...more

Foley & Lardner LLP

The Twelve Compliance Steps Every Multinational Corporation Should Undertake in Light of Recent Trump Administration Enforcement...

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Over the last month, regulators with the Trump administration sent a loud message to companies subject to U.S. jurisdiction: Enforcement of laws governing international activities is alive and well and the laws will continue...more

Butler Snow LLP

Comply With the U.S. Treasury’s OFAC Regulations and Avoid Possible Enforcement Action

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For a variety of reasons, the United States government prohibits foreign and domestic individuals, groups, companies and other entities from enjoying the benefits of participating in the U.S. economy. ...more

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