News & Analysis as of

Office of Foreign Assets Control (OFAC) Compliance

Guidepost Solutions LLC

Monitoring Against Whistleblower Retaliation

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Saves Lives, Prevents Major Crimes, and Accelerates Voluntary Self - Disclosures The U.S. Department of Justice (“DoJ”) recently spotlighted its Whistleblower Awards Program and Voluntary Self Disclosure (“VSDs”)...more

King & Spalding

Biden Administration Issues Proposed Rule Targeting “Connected Vehicles” Tied to China or Russia

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The Proposed Rule imposes substantial new reporting, diligence, and compliance obligations for companies in the automotive supply chain - On September 26, 2024, the U.S. Department of Commerce’s Bureau of Industry and...more

K2 Integrity

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

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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

Adams and Reese LLP

International Compliance Digest - September 2024

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New export controls, new section 301 duties, new OFAC requirements, new de minimis rule, new DOJ corporate compliance guidance, new international guidance on Russian sanctions. September had it all....more

Buchalter

Expanded Export Controls and Sanctions Require Heightened Compliance for All Industries

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A Changed Regulatory Environment – Companies who think that U.S. export controls and sanctions do not apply to their products and channels of trade should reassess that position. As an example, approximately US$1.1 billion in...more

The Volkov Law Group

OFAC’s Stated Concern About Foreign Companies and Domestic Sanctions Compliance and Post-Acquisition Compliance (Party IV of IV)

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Foreign companies with U.S. operations are struggling to navigate the landscape of sanctions compliance. OFAC has expressed its concern that foreign companies need to deploy U.S. based expertise and resources to ensure...more

The Volkov Law Group

Supply Chain Sanctions Liability — The Importance of Supply Chain Audits (Part III of IV)

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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

The Volkov Law Group

“The New FCPA”: The Future Landscape of Sanctions Enforcement (Part II of IV)

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We are all familiar with — over and over — third-party risks and FCPA risks. It is drilled in our collective heads — third-party risks and bribery. Legal and compliance professionals have to learn and understand the ins...more

American Conference Institute (ACI)

FCPA, Export Controls, and Sanctions Enforcement: Adjusting Compliance Strategies for the New Normal

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 Volkov Law Group

The Four Sanctions Compliance Cases that Everyone Should Know (Part I of IV)

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The Justice Department has repeated on several occasions that it intends to aggressively prosecute corporations for sanctions and export controls violations. The “New FCPA” is how the Justice Department characterizes its...more

American Conference Institute (ACI)

Developments in Global Sanctions Compliance with a Focus on Russia, Belarus and China

Sanctions imposed by the United States, the United Kingdom, and the European Union against Russia, China, and other parts of the world are fast-evolving. Such geopolitical shifts are creating new risks and placing further...more

Seward & Kissel LLP

Compliance Flash: Reminder to File the 2024 Annual Report of Blocked Property with OFAC

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Each year, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) requires all holders of blocked property to submit an Annual Report of Blocked Property (“ARBP”) setting forth all blocked...more

Adams and Reese LLP

International Compliance Digest – August 2024

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August was another robust month in international trade that further signifies the need for corporations to invest in effective compliance programs. For starters, the DOJ unveiled a new program that incentivizes corporate...more

BakerHostetler

Weekly Blockchain Blog - August 2024 #3

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Crypto Firms Announce New Products in Payments, Investments, Custody - A major U.S. digital asset management company recently announced the creation and public launch of its MakerDAO Trust, which “offers investors the...more

The Volkov Law Group

EU Revises Restrictive Measure “Best Practices” to Account for Adoption of OFAC 50% Rule Equivalent

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On July 3, 2024, the Council of the European Union (“EU Council”) officially promulgated a new set of best practices (“best practices” or “guidance”) for organizations seeking to comply with the latest sanctions regulations...more

Adams and Reese LLP

International Compliance Digest – July 2024

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July was a big month for compliance with a handful of reports and recommendations on due diligence and best practices concerning forced labor, export controls, sanctions from DHS, BIS, and OFAC. The below updates also...more

Guidepost Solutions LLC

Can a Failed Privacy Program Lead to Fentanyl Trafficking or OFAC Violations?

In July 2024, the Federal Bureau of Investigation and Department of Treasury’s Financial Crime Enforcement Network and Office of Foreign Assets Control (OFAC) released a joint notice discussing how Mexican-based Transnational...more

Society of Corporate Compliance and Ethics...

Is your reporting system worth $1 million?

Answering the question of how much money a compliance and ethics program saves an organization when there’s been a violation is often a very difficult task, which presents a challenge in defending the investment in a program....more

Seward & Kissel LLP

Compliance Flash: OFAC Announces New Reporting Requirement for Financial Institutions Under the REPO for Ukrainians Act

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The supplemental appropriations legislation signed into law on April 24, 2024 enacted numerous high-profile provisions addressing aspects of U.S. foreign policy and national security, including provisions that broaden and...more

The Volkov Law Group

OFAC Releases Guidance on Extended Statute of Limitations & Forthcoming Recordkeeping Changes

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The U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) has released updated guidance concerning recent legislation that doubled the statute of limitations for violations of certain sanctions and export control...more

Arnall Golden Gregory LLP

Q&A With Allison Raley: Defending Against Government Investigations

Q: What are the primary areas of focus in your practice related to government investigations? A: My practice primarily focuses on defense against enforcement actions brought by regulatory bodies such as the Office of Foreign...more

Ankura

Navigating OFAC Sanctions Risks in the Digital Realm: IP Addresses and Effective Controls

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In today's digital landscape, sanctions enforcement has become a critical concern for Financial Institutions (FIs). The borderless nature of cyberspace can make it difficult to monitor and regulate activities that may breach...more

Adams and Reese LLP

International Compliance Digest - June 2024

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Sanctions and export controls were the top items of interest in June. On the compliance side, OFAC and the BIS announced new sanctions and export controls on Russia and Belarus. The new measures target individuals and...more

Holland & Knight LLP

OFAC Expands Secondary Sanctions Targeting FFIs Transacting with Sanctioned Russian Persons

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Nearly six months after President Joe Biden signed an executive order (EO) authorizing secondary sanctions against Foreign Financial Institutions (FFIs) conducting or facilitating significant transactions with certain...more

The Volkov Law Group

Is Your Sanctions Compliance Program Compliant? — A Quick Five-Question Quiz

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Checklists can be handy — by simplifying and focusing on specific issues, a checklist can organize thinking and prioritize tasks. Here are five (5) questions that are fairly simple but revealing as to whether a company’s...more

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