I’m old enough to remember when seat belts were optional. And I remember people up in arms when seatbelt laws first passed. But now, my young adult children and their friends simply get in the car and buckle up without...more
On December 5, 2022, the Department of State, Directorate of Defense Trade Controls (“DDTC”) issued new Compliance Program Guidelines, “intended to provide an overview of an effective compliance program and an introduction to...more
Some may dismiss OFAC’s recent announcement last week that it issued a Finding of Violation to MidFirst Bank for violations of the Weapons of Mass Destruction Proliferators sanctions regulations as insignificant because OFAC...more
As we look past the Herbalife FCPA settlement with DOJ and the SEC for $123 million to resolve FCPA bribery and books and records violations, we are reminded of the variety of foreign government touchpoints and FCPA risks....more
9/10/2020
/ Books & Records ,
Bribery ,
China ,
Compliance ,
Corruption ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Herbalife ,
Popular ,
Risk Mitigation ,
White Collar Crimes
In these challenging times, when governments around the world are asking all “non-essential” workers to stay home, and companies are struggling with business interruptions and difficult decisions regarding pay-cuts, layoffs...more
4/21/2020
/ Business Closures ,
Business Continuity Plans ,
Business Interruption ,
Chief Compliance Officers ,
Compliance ,
Coronavirus/COVID-19 ,
Ethics ,
Furloughs ,
Layoffs ,
Risk Assessment ,
Wages
As the holidays quickly approach, consider sending a message from the Board or senior management reminding employees about your gift and hospitality policy....more
12/18/2019
/ Anti-Corruption ,
Best Practices ,
Compliance ,
Corporate Culture ,
Employer Liability Issues ,
Employment Policies ,
Ethics ,
FCPA Guidance ,
Holiday Gifts ,
Holidays ,
Risk Management ,
UK Bribery Act
On June 21, 2019, OFAC changed its requirements for reporting on blocked or rejected transactions under 31 C.F.R. §501.604. With little fanfare, the interim rule published in the Federal Register greatly expands the...more
On June 13, 2019, OFAC announced a settlement with Expedia Group, Inc. for violations of the Cuban Assets Control Regulations (“CACR”). (Available here). Expedia’s foreign subsidiaries assisted more than 2,200 individuals...more
6/17/2019
/ Audits ,
Compliance ,
Corporate Counsel ,
Corporate Monitoring ,
Cuba ,
Cuban Assets Control Regulations (CACR) ,
Economic Sanctions ,
Employee Training ,
Foreign Corporations ,
Foreign Subsidiaries ,
Iran ,
Iran Sanctions ,
ITSR ,
Office of Foreign Assets Control (OFAC) ,
Risk Mitigation
On Friday May 3, 2019, I attended the Rocky Mountain Securities Conference in Denver and heard from a number of regulators and industry experts, including SEC Commissioner Hester Peirce. ...more