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The United States manages more than three dozen separate economic and trade sanctions programs. Those programs target specified foreign governments along with thousands of named individuals, groups and entities in accordance...more
In our prior update (published November 29), we provided the first five steps in our twelve-step program for international compliance. These steps are intended to help companies identify international regulatory risk inherent...more
A recent OFAC enforcement action against MidFirst Bank highlights the five essential components of an effective sanctions compliance program that will serve to mitigate exposure in the event of a violation: Senior...more
How do you know if your sanctions compliance program (“SCP”) is really working? Can your firm really afford to find out the hard way – violations with major penalties, especially after regulators uncover your management did...more
For international businesses, the costs of a weak sanctions compliance program can be steep, impacting both a company’s reputation and its bottom line. This year alone, the Treasury Department’s Office of Foreign Assets...more
On May 2, 2019, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”)—the U.S. agency tasked with administering and enforcing the U.S.’s economic and trade sanctions programs—published A Framework for...more
OFAC outlines baseline considerations for evaluating a risk-based sanctions compliance program. On May 2, 2019, the US Treasury Department’s Office of Foreign Assets Control (OFAC) published A Framework for OFAC Compliance...more
The Office of Foreign Assets Control (OFAC), an agency of the U.S. Department of the Treasury, administers and enforces U.S. economic sanctions programs against targeted foreign governments, individuals, groups and entities...more
OFAC Provides Guidance on the Essential Components of a Risk-Based Sanctions Compliance Program - On May 2, 2019, the Office of Foreign Assets Control (“OFAC”) of the U.S. Department of the Treasury issued guidelines...more
• Russian corporations de-listed through significant specific steps agreed to with OFAC • Exporter settles for $7.7 million and agrees to comprehensive compliance measures • OFAC outlines sanctions compliance best...more