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
With the beginning of the aggressive trade enforcement era, companies need to focus on third-party risk and sanctions enforcement. The law, the practice, and the risks are important. As we embark on a new criminal enforcement...more
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
On July 2, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) reached a settlement with Key Holding, LLC (Key Holding) concerning its non-U.S. subsidiary’s violations of the Cuban Assets...more
Although the European Union and the United Kingdom did not introduce new sanctions against Russia over the summer, they extensively focused on the implementation of the existing measures and their enforcement. This week,...more
Global companies face significant risks in their supply chains of compliance with OFAC’s economic sanctions regime. OFAC has emphasized the importance of conducting supply chain risk assessments and audits....more
In line with the Biden administration’s declaration last year that anticorruption is a “core United States national security interest,” sanctions evasion enforcement rapidly has become a core priority for the Department of...more
•Many medical products can be exported to Iran – so long as a license is obtained •Imposition of successor liability underscores importance of pre-transaction due diligence •OFAC enforcement, as in the past, continues...more
ANTICORRUPTION DEVELOPMENTS - MTS Receives DOJ and SEC Declination Letters Concluding FCPA Investigations - On August 7, 2017, MTS Systems (MTS), a Minnesota based maker of test systems and industrial position...more
• This enforcement action highlights the heightened sanctions compliance and enforcement risk that companies face when engaging third-party consultants to perform due diligence on counterparties. U.S. persons must make clear...more
A recent federal appeals court decision addresses a familiar issue for many companies: When can a U.S. exporter be liable for a product that is re-exported to a sanctioned country, such as Iran? This update summarizes the...more