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Office of Foreign Assets Control (OFAC) Compliance Management Systems

The Volkov Law Group

Episode 384 -- Third-Party Risks and Sanctions

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With the beginning of the aggressive trade enforcement era, companies need to focus on third-party risk and sanctions enforcement. The law, the practice, and the risks are important. As we embark on a new criminal enforcement...more

Husch Blackwell LLP

The Justice Insiders Podcast - The Ever-Expanding Net: Corporate Compliance in an Era of Increasing Trade Sanctions and...

Husch Blackwell LLP on

Host Gregg N. Sofer welcomes Husch Blackwell partner Grant Leach to the program to discuss the burgeoning set of requirements and restrictions placed on U.S. businesses in connection with trade law. Gregg and Grant identify...more

Society of Corporate Compliance and Ethics...

Is your reporting system worth $1 million?

Answering the question of how much money a compliance and ethics program saves an organization when there’s been a violation is often a very difficult task, which presents a challenge in defending the investment in a program....more

Ballard Spahr LLP

ICBC Agrees to Two Consent Orders for Alleged BSA/AML Deficiencies and Disclosure of Confidential Supervisory Information

Ballard Spahr LLP on

Recently, the Industrial and Commercial Bank of China Ltd. (“ICBC”) entered into two consent orders. The first consent order is with the New York State Department of Financial Services (the “NYDFS”) for alleged deficiencies...more

The Volkov Law Group

Justice, Commerce and Treasury Departments Issue Comprehensive Tri-Party Voluntary Disclosure Guidelines for Sanctions and Export...

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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

The Volkov Law Group

Five Practical Steps to Elevate Your Sanctions Compliance Program (Part III of III)

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Even with the current focus on sanctions compliance, many companies have done little to assess and enhance their existing sanctions compliance program.  Instead, a number of companies have stitched together a basic sanctions...more

The Volkov Law Group

Refreshing and Elevating Your Sanctions Compliance Program (Part II of III)

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Let’s move beyond the headline – trade compliance is the new FCPA.  We get it.  The next step is to do something about it.  The Justice Department has repeated this refrain – it is one of its greatest hits.  In addition, DOJ,...more

NAVEX

A Review of Risk & Compliance in 2022

NAVEX on

As 2022 comes to a close, now is an ideal time to reflect on the developments and challenges this year held for the risk and compliance profession – and there was no shortage of either. The complexity of maintaining...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

The Volkov Law Group

Takeaways from OFAC’s Sanctions Compliance Guidance for Virtual Assets and Cryptocurrency

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In early October, OFAC released a guidance brochure on sanctions compliance, specifically tailored for the cryptocurrency and virtual assets industry.  For seasoned compliance veterans, it ends up reading like a refresher...more

The Volkov Law Group

The Elevation of Sanctions Compliance

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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

The Volkov Law Group

Five Basic Steps to Implement a Sanctions Compliance Program

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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

Lowenstein Sandler LLP

Compliance Program "Must Haves" For Doing Business Abroad

Lowenstein Sandler LLP on

With "compliance" being the buzzword for corporate executives and legal counsel, there is renewed focus on reducing legal risks when exporting or selling overseas. The key is a robust compliance program that outlines the...more

Foodman CPAs & Advisors

Financial Institutions Can No Longer Afford to Underfund Compliance Hiring and Training

The Covid-19 Pandemic and the accompanying reduction in economic activity has been a rationale for Financial Institutions (FI) to re-analyze their budgets for compliance training and education.  FIs, as well as  businesses in...more

Foodman CPAs & Advisors

Cumplimiento OFAC de las Instituciones Financieras y las Agencias Reguladoras Bancarias

Mientras que la OFAC es responsable de promulgar, desarrollar y administrar sanciones para el Secretario del Tesoro de EE. UU., las agencias reguladoras bancarias cooperan para asegurar el cumplimiento de las instituciones...more

Foodman CPAs & Advisors

Financial Institution OFAC Compliance and Bank Regulatory Agencies

While OFAC is responsible for promulgating, developing, and administering sanctions for the U.S. Secretary of the Treasury, bank regulatory agencies cooperate in ensuring OFAC financial institution compliance.  ...more

Cadwalader, Wickersham & Taft LLP

COVID-19 Update: Are You For Real? Due Diligence in the Age of Coronavirus

In the context of COVID-19, there are significant challenges involved in conducting due diligence: hard-copy documents are inaccessible, in-person meetings have moved online, and on-site visits may be impossible....more

Foodman CPAs & Advisors

What can trigger an OFAC investigation and what can an OFAC Investigation lead to?

OFAC investigations are often triggered as a result of: • Reports that are generated by U.S. Financial Institutions which have blocked or rejected a transaction based on a suspected sanctions violation • A self-disclosure...more

Foodman CPAs & Advisors

Who are you partnering with for your Financial Institution’s BSA/AML Independent Testing?

Financial Institutions ought to design and evaluate compliance programs to meet BSA/AML requirements and to satisfy Bank Examiner expectations. A Financial Institution’s Compliance Programs must comply with the requirements...more

Thomas Fox - Compliance Evangelist

Four Compliance Insights for 2020 and Beyond

Compliance Convergence. In 2019 there were three significant releases of information by the federal government which directly impacted compliance professionals. Two came from the Department of Justice (DOJ) and one came from...more

Thomas Fox - Compliance Evangelist

Introducing New 2020 Podcast Series – 31 Days to a More Effective Compliance Program

2019 has been a very significant year for every compliance practitioner and compliance program. There were three significant releases of information by the federal government which directly impacted compliance professionals...more

The Volkov Law Group

Apple Pays $467K to OFAC for Sanctions Violations

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Even the mighty can fall – Apple agreed to pay OFAC $467k for violations of the Foreign Narcotics Kingpin Sanctions regulations. In 2008, Apple entered into an applications development agreement with SIS, a Slovenian...more

Thomas Fox - Compliance Evangelist

Antitrust Compliance Programs: Part 2 – Elements of an Effective Compliance Program (Elements 1-4)

As the third in a triumvirate of releases on compliance programs, the Department of Justice (DOJ) Antitrust Division, in July the released its Evaluation of Corporate Compliance Programs in Criminal Antitrust Investigations...more

The Volkov Law Group

Watching the River Flow: The Evolution and Future of Compliance (Part I of III)

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Bob Dylan, Watch the River FlowI have to admit it – I still love to listen to Bob Dylan.  With age, his lyrics resonate more and more.  HERE is a nice version of Watch the River Flow in case you want to listen while reading...more

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