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Policies and Procedures Office of Foreign Assets Control (OFAC)

Thomas Fox - Compliance Evangelist

Compliance into the Weeds: Sanctions Compliance Failures: Lessons from Harman International and Interactive Brokers

The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting...more

Foley Hoag LLP

OFAC Publishes Both Interim Final Rule Extending Recordkeeping Requirements and Comment Request Regarding its Information...

Foley Hoag LLP on

OFAC issued an interim final rule extending OFAC’s recordkeeping requirements from 5 years to 10 years, to comport with the corresponding statute of limitations extension. OFAC also published a request for public comment...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

Holland & Hart LLP

Guidance on Extension of Statute of Limitations for Civil and Criminal Violations of Sanctions Authorities

Holland & Hart LLP on

On July 22, 2024, the Office of Foreign Assets Control (“OFAC”) published guidance regarding recent legislation extending the statute of limitations for civil and criminal violations of the International Emergency Economic...more

Braumiller Law Group, PLLC

Hot Topics in International Trade - June 2024 - New Legislation Extends Statute of Limitations for Sanctions Violations

Recently, President Biden signed a foreign military support bill (H.R. 815) into law, which also encompassed the 21st Century Peace Through Strength Act (the Act), a legislative proposal introduced in the House containing...more

King & Spalding

New Ten-Year Statute of Limitations for Sanctions Violations

King & Spalding on

Implications Related to the Doubling of the Statute of Limitations for Civil and Criminal Violations of Two Primary Sanctions Authorities - SUMMARY - On April 24, 2024, President Biden signed into law a foreign military...more

Guidepost Solutions LLC

Emerging Expectations from the Latest Enforcement Actions Over Off-Channel Communications

Since December 2021, the U.S. Securities and Exchange Commission (SEC) and Commodity Futures Trading Commission (CFTC) have levied almost $3.0 billion in penalties for longstanding failures by 39 broker-dealers, swap dealers,...more

Seward & Kissel LLP

The Importance of Sanctions and Export Control Compliance

Seward & Kissel LLP on

The United States manages more than three dozen separate economic and trade sanctions programs. Those programs target specified foreign governments along with thousands of named individuals, groups and entities in accordance...more

Oberheiden P.C.

OFAC Compliance: Developing and Implementing an Effective Sanctions Compliance Program

Oberheiden P.C. on

Financial institutions and companies that are subject to oversight from the Office of Foreign Assets Control (OFAC) need to prioritize compliance. OFAC has become increasingly active in recent years, and it is devoting...more

Oberheiden P.C.

OFAC Compliance: Avoiding Common Root Causes of Compliance Policy Breakdowns and Deficiencies

Oberheiden P.C. on

For financial institutions and businesses that are subject to the oversight of the Office of Foreign Assets Control (OFAC), compliance needs to be a priority in 2023. OFAC is playing an increasingly active role in overseeing...more

Morrison & Foerster LLP

Risk Alert: Broker-Dealers Must Comply with Their AML and Sanctions Obligations

On July 31, 2023, the Securities and Exchange Commission’s (SEC) Division of Examinations (EXAMS) issued a risk alert summarizing observations from its recent anti-money laundering (AML) and counter-financing of terrorism...more

Bass, Berry & Sims PLC

Tri-Seal Compliance Note on Voluntary Self-Disclosure Released by Departments of Commerce, Justice, and Treasury

On July 26, the Department of Commerce, Department of the Treasury, and Department of Justice released a Tri-Seal Compliance Note (July Note) providing guidance on voluntary self-disclosure of potential violations of U.S....more

Torres Trade Law, PLLC

Trade Alert: Justice, Commerce, and Treasury Departments Issue a Tri-Seal Compliance Note on Voluntary Self-Disclosures

Torres Trade Law, PLLC on

On July 26, 2023, the Department of Justice (“DOJ”), the Department of Commerce’s Bureau of Industry and Security (“BIS”), and the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published their second...more

Ballard Spahr LLP

Consumer Finance Monitor Podcast Episode: A Look at the Treasury Department’s April 2023 Report on Decentralized Finance or “DeFi”

Ballard Spahr LLP on

The report examines the vulnerabilities in DeFi, including potential gaps in the United States’ Bank Secrecy Act/anti-money laundering regulatory, supervisory, and enforcement regimes for DeFi. We first discuss how Treasury...more

Morgan Lewis

Conducting Effective Sanctions and Anti-Money Laundering Diligence on Non-Latin-Based Entities

Morgan Lewis on

With the ever-increasing use of sanctions as a foreign policy tool (or weapon), sanctions compliance has taken on greater importance than ever. Moreover, as countries increase extraterritorial applications of their sanctions,...more

Seward & Kissel LLP

OFAC Issues Determination and Guidance For Russian Oil Price Cap Policy Commencing Today

Seward & Kissel LLP on

As noted in our prior alerts (concerning OFAC’s September 9, 2022 preliminary guidance and October 31, 2022 follow-on FAQ clarifying the applicability of the impending price cap policy) the U.S. Department of the Treasury’s...more

WilmerHale

PTAB/USPTO Update - June 2022

WilmerHale on

USPTO Leadership - ..In May, USPTO Director Kathi Vidal delivered official remarks at the International Trademark Association (INTA) Annual Convention, the Patent Public Advisory Committee (PPAC), and the Advanced...more

Lowenstein Sandler LLP

Trade Matters, February 2022: A monthly newsletter covering global trade & national security developments

1. Treasury Mandates Reporting of Foreign Securities Holdings of $200M or More- All U.S. persons (custodians and end investors) who manage $200 million or more in foreign securities for themselves or others must file a...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

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

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

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

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

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