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
On June 16, 2025, the Department of Justice (DOJ) National Security Division (NSD) and the US Attorney’s Office for the Southern District of Texas announced the first declination of prosecution for an acquirer that...more
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
Córdoba Music Group LLC (Córdoba), a manufacturer of musical instruments based in California, has agreed to pay $41,591 to settle its civil liability for violations of sanctions on Iran. On nine occasions, Córdoba shipped...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
The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has released a $7.45 million penalty against State Street Bank and Trust Company and its non-bank, fintech subsidiary Charles River Systems for...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
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
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
When it comes to OFAC sanctions violations, honesty is the best policy. Promptly and voluntarily disclosing violations upon their discovery can pay serious dividends. ...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
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
In another significant step notifying global businesses of the new realities – companies are about to face aggressive coordinated criminal and civil prosecutions for sanctions and export control violations. The last piece in...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 Department of Justice is pushing its commitment to voluntary disclosure programs. Companies, however, are not lining up at DOJ’s door. The balance between sitting tight or voluntary disclosures requires care....more
U.S. companies with international clients or customers have to comply with far more laws and regulations than companies that only operate domestically. These include laws and regulations enforced by the U.S. Office of Foreign...more
Comtech Telecommunications (“Comtech”) and Comtech EF Data Corp. (“EF Data”) agreed to pay OFAC $894,111 for violations of the Sudan Sanctions Program. ...more
On July 8, the U.S. Department of the Treasury announced a settlement with Amazon.com, Inc., related to the company's potential civil liability for apparent violations of multiple sanctions programs resulting from...more
A government inquiry can result in serious consequences for a company or individual. Our new podcast series, Voluntary Disclosure—brought to you by the lawyers in our investigations, enforcement, and white collar practice—is...more
In 2019, the Department of Treasury’s Office of Foreign Asset Control (OFAC) issued important guidance on sanctions compliance programs. OFAC’s guidance sets out new and prescriptive requirements for sanctions compliance...more
• Actions underscore long arm of U.S. sanctions jurisdiction • Voluntary disclosures and cooperation can lead to significant penalty reductions • Facilitation of a violation is treated the same as a direct violation ...more
In December 2019, the Department of Justice (“DOJ”) announced a new Export Control and Sanctions Enforcement Policy for Business Organizations (the “Policy”) regarding voluntary self-disclosures of potentially criminal...more
On December 13, 2019, the Department of Justice (DOJ) updated its enforcement guidelines to include a no-fine, no-prosecution presumption for companies that voluntarily self-disclose potentially willful violations of the...more