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Risk Assessment Internal Controls Economic Sanctions

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

Venable LLP

Nonprofits Operating Abroad: Five Key Compliance Strategies

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With the current state of the world and heightened scrutiny of the nonprofit sector, it is critical that nongovernmental organizations (NGOs) with international reach routinely assess the effectiveness of their trade...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

Society of Corporate Compliance and Ethics...

[Virtual Event] Corporate Compliance Enforcement Conference - July 25th, 9:00 am - 4:45 pm CT

Is Your Compliance Program Designed for the Current Enforcement Landscape? Data protection, anti-corruption, antitrust, supply chains, economic sanctions and even the software employees use to communicate are all subjects...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

Guidepost Solutions LLC

Is Your Russia–Ukraine And Overall Sanctions Compliance Program Really Working? (Don’t Find Out the Hard Way)

How do you know if your sanctions compliance program (“SCP”) is really working? Can your firm really afford to find out the hard way – violations with major penalties, especially after regulators uncover your management did...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

K2 Integrity

What the Biden Administration Brings on Sanctions

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Despite a shift in the sanction landscape, it will take time for enforcement activity to catch up. As a result, organizations should regularly examine their exposure with business partners around the globe and consult with...more

The Volkov Law Group

Five Basic Steps to Implement a Sanctions Compliance Program

The Volkov Law Group on

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

K2 Integrity

Applying Expensive Lessons Learned: The Importance of an Effective Sanctions Compliance Program

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For international businesses, the costs of a weak sanctions compliance program can be steep, impacting both a company’s reputation and its bottom line. This year alone, the Treasury Department’s Office of Foreign Assets...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

The Volkov Law Group

Five Common Weaknesses in OFAC Sanctions Compliance Programs

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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

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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

Hogan Lovells

U.S. Sanctions regulator outlines expectations for Global Sanctions Compliance: impact on Private Equity

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On 2 May 2019, the U.S. Treasury's Office of Foreign Assets Control ("OFAC"), the agency responsible for enforcing economic sanctions, published "A Framework for OFAC Compliance Commitments" (the "Framework") which outlines...more

Hogan Lovells

OFAC outlines expectations for global sanctions compliance

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On 2 May 2019 the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) issued "A Framework for OFAC Compliance Commitments" (the framework), which outlines five components OFAC considers to be essential...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

Putting Together Your Sanctions Compliance Program: Management Commitment (Part I of IV)

The Volkov Law Group on

If you follow my blog, you know I am not one to embrace hyperbole.  So, forgive me for stretching a little here, but the OFAC Framework for Sanctions Compliance Programs is a game changer.  Let me explain why I am saying...more

Seyfarth Shaw LLP

Culture of Compliance: M&A Transactions Subject To U.S. Department of Treasury Scrutiny

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Seyfarth Synopsis: On May 2, 2019, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) released explicit guidance outlining its expectations for effective written sanctions compliance programs...more

Dorsey & Whitney LLP

OFAC Issues Sanctions Guidance and the Concept of Culture Gains Traction (With Chinese Translation)

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

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

The Volkov Law Group

OFAC Framework for Sanctions Compliance Programs – Risk Assessment and Internal Controls (Part II of IV)

The Volkov Law Group on

OFAC’s Framework for Sanctions Controls Program is a heightening of the importance of ethics and compliance program and reflects significant expectations for implementing effective compliance strategies. ...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

Latham & Watkins LLP

OFAC’s 5 Essential Components of an Effective Sanctions Compliance Program

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OFAC outlines baseline considerations for evaluating a risk-based sanctions compliance program. On May 2, 2019, the US Treasury Department’s Office of Foreign Assets Control (OFAC) published A Framework for OFAC Compliance...more

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