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Office of Foreign Assets Control (OFAC) Internal Controls White Collar Crimes

Stankie Law

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

Stankie Law on

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

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

Womble Bond Dickinson

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

Womble Bond Dickinson on

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

The Volkov Law Group

OFAC Screening and Internal Controls

The Volkov Law Group on

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

The Volkov Law Group

Apple Pays $467K to OFAC for Sanctions Violations

The Volkov Law Group on

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

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 3 – Internal Controls

I am in a multipart series on the Framework for OFAC Compliance Commitments (Framework). Every compliance professional of any stripe needs to read, understand and implement some of the key concepts of the Framework into your...more

Thomas Fox - Compliance Evangelist

Antitrust Compliance Programs: Part 3 – Elements of an Effective Compliance Program (5-9)

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

The Volkov Law Group

Five Common Weaknesses in OFAC Sanctions Compliance Programs

The Volkov Law Group on

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

The Volkov Law Group

Five Important Mandates from OFAC Compliance Framework

The Volkov Law Group on

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

The Volkov Law Group

Making Sure Your Internal Controls Address Sanctions Risks (Part III of IV)

The Volkov Law Group on

The term “internal controls” is a loaded one – it morphs in various ways depending on the context.  Sometimes it is a shorthand for financial accounting controls; other times it encompasses a company’s compliance controls...more

The Volkov Law Group

Conducting a Sanctions Risk Assessment: A New Era for Analyzing Your Risks (Part II of IV)

The Volkov Law Group on

OFAC’s new framework guidance for sanctions compliance programs stretched into new territory with its risk assessment requirement.  This new approach reflects OFAC’s recent aggressive enforcement programs....more

The Volkov Law Group

OFAC Joins the Compliance Club – Issues Framework for Sanctions Compliance Programs (Part I of IV)

The Volkov Law Group on

On the heels of the Justice Department’s announcement of its new compliance guidance, on May 2, 2019, the Treasury Department’s Office of Foreign Asset Control (“OFAC”) issued its promised guidance for sanctions compliance...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - November 2018

ANTICORRUPTION DEVELOPMENTS - Deputy Attorney General Rod Rosenstein Announces Pursuing Individuals Will be a “Top Priority” for Corporate Enforcement Actions - On November 29, 2018, Deputy Attorney General Rod J....more

Foley & Lardner LLP

White Collar Enforcement and the New Trump Administration: Your Top Ten Questions Answered

Foley & Lardner LLP on

Enforcement activity under the Obama administration often made headlines for the eye-popping level of fines, with the Foreign Corrupt Practices Act (FCPA), Anti-Money Laundering (AML) regulations, and economic sanctions...more

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