Episode 324 -- Third-Party Risks and Sanctions Compliance
FINCast Ep. 39 – State of Russia Sanctions Two Years After the Invasion
Understanding the Additional Risks When Making a Ransomware Payment
Looking The Other Way: Recent Cases Of AML And Sanctions Failings In Scandinavia
Episode 118 -- Update on OFAC Enforcement and Lessons Learned
This is the final in our 2025 Year in Preview series examining important trends in white collar law and investigations in the coming year. Throughout 2024, enforcement of international trade laws continued to gather pace...more
Looking for something more advanced than your average export controls conference? Go beyond the basics at ACI’s 2nd Annual Advanced Forum on Global Export Controls. This premier event offers cutting-edge insights and...more
Despite a relatively slow year in OFAC sanctions enforcement, OFAC closed 2024 with a string of settlements in five cases, including its second in 2024 against an individual defendant. While OFAC had a slow year, DOJ...more
As the interplay between export controls, trade sanctions, and anticorruption enforcement continues to intensify, multinational companies must remain vigilant in ensuring that their compliance programs address the many...more
On April 24, 2024, President Biden signed into law H.R. 815 (Pub. L. 118-50), “Making emergency supplemental appropriations for the fiscal year ending September 30, 2024, and for other purposes” (the “Act”), which includes...more
In this new era of aggressive sanctions enforcement, companies have to understand the red lines that define where criminal and civil enforcement risk increase. In contrast to the history of FCPA enforcement, DOJ and OFAC...more
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
Congress has doubled the statute of limitations for violations of most U.S. sanctions programs administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control. Companies should be aware of the...more
Following months of delays and intense debate in Congress, President Biden signed H.R. 815 into law on April 24, 2024, which made headlines for funding $95 billion in military aid to Ukraine, Israel, and Taiwan, along with...more
While media reporting has predominantly focused on the provisions in the emergency foreign aid package that President Biden signed into law on April 24, 2024 that provides funding for Ukraine, Israel and Taiwan, House Foreign...more
As DOJ, OFAC and BIS ramp up sanctions and export controls enforcement, they have continued to provide important compliance guidance. You have to give the enforcement agencies credit — on the one hand, they regularly warn of...more
February saw a continuing focus on Russia. First, the Treasury Department’s Office of Foreign Assets Control (OFAC), in conjunction with the State Department, sanctioned over 500 individuals and entities – the “largest number...more
Today’s alert—the second in our Sanctions 2023 Year in Review Series—provides an overview of U.S. sanctions enforcement in 2023, including the key lessons learned from the public enforcement actions issued by the U.S....more
We previously have blogged on actions taken by the DOJ’s “Task Force KleptoCapture,” an interagency law enforcement task force with a mandate to target sanctioned Russian and pro-Russian oligarchs. While explicitly launched...more
December saw continuing enforcement actions involving Russia. First, the Treasury Department’s Office of Foreign Assets Control (OFAC) settled investigations into apparent sanctions violations by a New York-based insurance...more
Within the trade bar there is cautiousness, curiosity and skepticism at the numerous pronouncements signaling greater enforcement of export controls and sanctions by the Bureau of Industry and Security, the Office of Foreign...more
You are reading the November 2023 Update of the Bass, Berry & Sims Enforcement Roundup, where we bring notable enforcement actions, policy changes, interesting news articles, and a bit of our insight to your inbox. ...more
As we have repeatedly noted in the context of other blog posts and webinars in which various representatives of The Volkov Law Group have participated, the violation of existing U.S. sanctions and export control regulations...more
The past few months have seen numerous high-profile enforcement actions highlighting an increasing trend, what Deputy Attorney General Lisa Monaco called “the biggest shift in corporate criminal enforcement that I’ve seen...more
In October, deputy attorney general Lisa Monaco made headlines when she announced a new leniency policy at the U.S. Justice Department for companies that disclose compliance violations discovered during mergers and...more
On November 21, 2023, the U.S. Office of Foreign Assets Control (OFAC) announced its largest settlement in history with the virtual currency exchange Binance. This almost-billion dollar settlement is a part of a larger...more
Over the last several months, companies have become entangled in an increasingly complex web of new and expanded sanctions and export control restrictions related to Russia in response to its war on Ukraine. The current...more
Companies faced with the decision of whether to voluntarily self-report sanctions breaches to law enforcement or sanctions enforcement agencies in the UK and the US can take some measure of comfort from recent comments made...more
The Justice Department has touted the upcoming wave of corporate prosecutions for criminal sanctions violation as the era of “The New FCPA.” DOJ’s reference is intended to communicate a strong message – companies are going to...more