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
The Department of Justice’s (DOJ) recent announcement that it would decline to prosecute a self-reported criminal export control violation demonstrates the continuing importance of prompt, voluntary self-disclosure (VSD) and...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
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
Key Points - On May 21, 2024, the DOJ announced its first ever declination under the NSD’s updated Enforcement Policy, declining to prosecute Sigma-Aldrich Inc., d/b/a MilliporeSigma (a subsidiary of Merck KGaA, Darmstadt,...more
Companies and their executives can reduce Department of Justice (DoJ), OFAC, and Commerce Department risks (and liability) by understanding and respecting the relationship between economic sanctions, voluntary...more
On March 7, 2024, the US Department of Justice’s National Security Division (NSD) released a revised Voluntary Self-Disclosure (VSD) Policy (the “VSD Policy”). The VSD Policy substantially tracks the language of the previous...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
On July 26, 2023, the departments of Commerce, Justice and the Treasury issued their second ever to date “Tri-Seal Compliance Note” (the “Note”). It describes expectations for the voluntary disclosure of sanctions, export,...more
On June 26, 2023, the Departments of Justice, Commerce, and Treasury issued a Tri-Seal Compliance Note that summarizes agency policy memoranda and existing regulations on voluntary self-disclosures (VSDs) of export controls...more
The Justice Department is often criticized for its lack of transparency. But when it comes to policy changes or initiatives, DOJ is more than transparent – DOJ always tells the public what it plans to do and then does it....more
On December 13, 2019, the National Security Division (“NSD”) of the U.S. Department of Justice (“DOJ”) released a revised enforcement policy (“the Policy”) meant to encourage companies to voluntarily self-disclose potentially...more