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Office of Foreign Assets Control (OFAC) Compliance Corporate Governance

Thomas Fox - Compliance Evangelist

2 Gurus Talk Compliance – Episode 54 – The FCPA is Back On Edition

What happens when two top compliance commentators get together? They talk compliance, of course. Join Tom Fox and Kristy Grant-Hart in 2 Gurus Talk Compliance as they discuss the latest compliance issues in this week’s...more

Foley & Lardner LLP

The Non-Compliant Cat in the Hat

Foley & Lardner LLP on

So, just before Easter, in 1957, a little book you may have heard of, called The Cat in the Hat, made its first appearance. Theodore Geisel — writing under the name “Dr. Suess” — later said that of all his children’s books,...more

Jenner & Block

Client Alert: Post-Conflict Reconstruction: Opportunities and Risks

Jenner & Block on

After years of destabilizing international and non-international armed conflict that has resulted in the loss of lives, destruction of communities, and decimation of economic opportunity in places across the globe, there are...more

The Volkov Law Group

C.H. Robinsom Settles with OFAC for $257,690 to Resolve Iran and Cuba Sanctions Violations

The Volkov Law Group on

C.H. Robinson International Inc. (CHR), a Minnesota-based global transportation and logistics company, has agreed to pay $257,690 to settle civil liability for 82 apparent violations of sanctions against Iran and Cuba...more

The Volkov Law Group

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

The Volkov Law Group on

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)

The Volkov Law Group on

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

The Volkov Law Group

Troubling Trends: The CCO’s Authority, Independence and Access to Resources (Part II of III)

The Volkov Law Group on

While my first posting highlighted the positive developments in the CCO’s role and professional development, the next two postings present troubling concerns....more

The Volkov Law Group

Gatekeeper Misfires and Corporate Governance Failures

The Volkov Law Group on

Here is another obvious point – internal controls are intended to ensure compliance with relevant policies and procedures.  Internal controls are not just for show, or not just limited to financial reporting.   A compliance...more

The Volkov Law Group

Ethics and Compliance Trends and Predictions for 2020

The Volkov Law Group on

2019 was a big year for ethics and compliance.  In fact, it is easy to argue that since the adoption of the compliance provisions in the US Sentencing Guidelines in 1991, compliance had its biggest year....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

Thomas Fox - Compliance Evangelist

The OFAC Compliance Framework: Element 4 & 5 – Testing and Auditing & Training

After a short visit to Val Lewton’s Cat People, I return to conclude this multipart series on the Framework for OFAC Compliance Commitments (Framework). Every compliance professional of any stripe needs to read, understand...more

Thomas Fox - Compliance Evangelist

The OFAC Compliance Framework: Element 1 – Management Commitment

Yesterday, while honoring Ginger Baker who passed away this weekend, I began a multipart series on the Framework for OFAC Compliance Commitments (Framework). Mike Volkov has called this Framework a “game-changer” and has...more

Thomas Fox - Compliance Evangelist

Farewell to Ginger Baker and Welcome to the OFAC Compliance Framework

The past few months have provided the compliance professional with two very useful releases of information from the Department of Justice (DOJ) around compliance programs. April saw the release of the Evaluation of Corporate...more

The Volkov Law Group

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

The Volkov Law Group on

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

Sheppard Mullin Richter & Hampton LLP

Feds Focus on Individuals in Evaluating Corporate Compliance Programs

Earlier this month, the U.S. Department of Justice (“DOJ”) and the U.S. Department of the Treasury’s Office of Foreign Asset Controls (“OFAC”) both issued guidance regarding their expectations for corporate compliance...more

Dorsey & Whitney LLP

OFAC Issues Sanctions Guidance and the Concept of Culture Gains Traction

Dorsey & Whitney LLP on

On May 2, 2019, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”)—the U.S. agency tasked with administering and enforcing the U.S.’s economic and trade sanctions programs—published A Framework for...more

Eversheds Sutherland (US) LLP

Recent guidance brings OFAC in line with domestic and global compliance trends

On May 2, 2019, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued guidance titled “A Framework for OFAC Compliance Commitments” (Guidance), providing direction regarding what OFAC considers to...more

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