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Compliance Russia Foreign Policy

Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory violations. ... more +
Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory violations.  In response to many corporate scandals evidencing rampant unethical business practices, many nations, including the United States, began passing strict regulatory frameworks aimed at curbing these abuses. Notable pieces of legislation in this area include the U.S. Foreign Corrupt Practices Act (FCPA), Sarbanes-Oxley (SOX), and the U.K. Bribery Act, to name a few. The foregoing statutes and the severe penalties often associated with them form the basis of many modern institutional compliance programs. less -
The Volkov Law Group

UK’s OFSI Imposes £15,000 Penalty on Property Management Company for Sanctions Violations

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In late August 2024, the UK’s Office of Financial Sanctions Implementation (“OFSI”), a department within HM Treasury, imposed a monetary penalty of £15,000 on Integral Concierge Services Limited (“ICSL”)—a UK-based property...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

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

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

Mayer Brown

Russia/Ukraine Sanctions Update - Month of February

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I. US SANCTIONS - US Department of the Treasury Sanctions Almost 300 Individuals and Entities: On February 23, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned almost 300 individuals...more

The Volkov Law Group

OFAC Bolsters Russian Oil Price Cap Record-Keeping Requirements in New Round of Sanctions

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The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has renewed its commitment to squeezing Russia’s oil proceeds, releasing updated guidance with enhanced attestation and record-keeping requirements...more

The Volkov Law Group

U.S. Government Charges Parties with Violating U.S. Sanctions and Export Control Laws

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As we have repeatedly noted in the context of other blog posts and webinars in which various representatives of The Volkov Law Group have participated, the violation of existing U.S. sanctions and export control regulations...more

Seward & Kissel LLP

Compliance Flash: OFAC Alert Warns U.S. Persons About Possible Evasion of Russian Crude Oil Price Cap

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On April 17, 2023, the United States Treasury Department’s Office of Foreign Assets Control (OFAC) issued an alert warning U.S. persons about possible evasion of the price cap on Russian Federation origin crude oil,...more

The Volkov Law Group

Former Special Agent in Charge of the FBI New York Counterintelligence Division Charged with Violating Russia Sanctions

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In an ironic twist (or you just can’t make this up moment, whichever you prefer), the Justice Department announced the arrest of Charles McGonigal, the former Special Agent in Charge (“SAC”) of the FBI’s Counterintelligence...more

The Volkov Law Group

Person of the Year: The Trade Compliance Officer

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I admit I may be a little late in completing some of my 2022 retrospective postings.  Nevertheless, I have to announce Corruption, Crime & Compliance’s Person of the Year Award.  Although my posting is not done with as much...more

K2 Integrity

[Webinar] Russia Sanctions: 2022 Review and 2023 Outlook - January 18th, 7:00 am ET

K2 Integrity on

In this webinar, you’ll hear from expert panelists Julia Khersonsky, acting director of the U.S. Department of State’s Export Control and Border Security Bureau (EXBS); Chip Poncy, global head of financial integrity at K2...more

The Volkov Law Group

OFAC Due Diligence and Attestation Requirements (Part IV of IV)

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OFAC’s guidance is intended to ease the burden on an otherwise difficult compliance problem.  Companies have to act in good faith to avoid transacting business involving Russian crude oil that has been sold above the $60 per...more

BCLP

Liquidating Frozen Assets: When Foreign Policy Meets Sanctions Enforcement

BCLP on

In their June 2022 report “The cost of complacency: illicit finance and the war in Ukraine”, the House of Commons Foreign Affairs Committee (the “FAC”) condemned the UK Government’s historic lack of commitment to tackling...more

The Volkov Law Group

Avoiding Compliance Overkill — Properly Assess and Manage Tangible Risks

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The uptick in recent sanctions activity caused in large part by the Russian Federation’s unprovoked and unilateral invasion of Ukraine has caused absolute pandemonium in many compliance circles. While the U.S. Department of...more

The Volkov Law Group

Sanctions Enforcement: “The New FCPA”

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Hold onto your hats – while we are on the cusp of more FCPA enforcement actions, the Justice Department and OFAC are gearing up for real and significant sanctions enforcement actions.  The dye is cast, so here we go. ...more

The Volkov Law Group

OFAC Settles with S&P Global for $78,750 for Violations of Ukraine-Russia Sanctions Program

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Prosecutors and regulators are scouring their files for enforcement actions – criminal and civil – for violations of the 2014 Ukraine-Russia Sanctions Program.  The message being sent is clear – do not violate any sanctions...more

The Volkov Law Group

Global Update and Review: Russia Sanctions and Asset Capture Initiatives

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The Russia-Ukraine crisis has created a fast-moving compliance nightmare – sanctions and export controls around the globe are changing each day.  Some major companies are pulling out of Russia completely in response to the...more

The Volkov Law Group

Sanctions Updates: Cuba, North Korea, Russia, Sudan, Venezuela

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Sanctions compliance is challenging because of the changing nature of sanctions regulations and individuals identified as Specially Designated Nationals. With each new administration, foreign policy priorities are usually...more

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