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Self-Disclosure Requirements Enforcement Actions Financial Institutions

The Volkov Law Group

Interactive Brokers Settles with OFAC for $11.8 Million for Violations of Multiple Sanctions Programs

The Volkov Law Group on

The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced on July 15, 2025, that Interactive Brokers LLC (“IB”)—a globally active electronic brokerage firm headquartered in Greenwich,...more

Skadden, Arps, Slate, Meagher & Flom LLP

DOJ Unveils White Collar Enforcement Overhaul: New Incentives, Streamlined Policies and Expanded Whistleblower Rewards

Revisions to Department of Justice (DOJ) white collar enforcement policies provide enhanced incentives for voluntary self-disclosure and clarify the consequences of failing to disclose wrongdoing. At the same time, expanded...more

K2 Integrity

First Ever Targeted Guidance On Financial Institutions’ Compliance With Export Administration Regulations

K2 Integrity on

On 9 October 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) published its first ever unilateral guidance specifically addressed to financial institutions (FIs). The Guidance to Financial...more

Bass, Berry & Sims PLC

International Trade Enforcement Roundup – January 2023

Russia - Former Special Agent in Charge of the FBI New York Counterintelligence Division Charged with Violating U.S. Sanctions on Russia (DOJ) Those involved. Charles McGonigal, former Special Agent in Charge of the FBI...more

Orrick, Herrington & Sutcliffe LLP

DOJ Updates Its Approach to Encourage Voluntary Self-Disclosures of Export Control and Sanctions Violations

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

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