Nonprofit Basics: Insider Transactions and Nonprofits – What’s the Big Deal?
Point By Point: Abbey Ruby Talks Commercial Finance, DEI Efforts, and Working At Waller
The Impact of War on Commercial Contracts and the Global Supply Chain
Cryptocurrency: Wild West or Wall Street? [More with McGlinchey, Ep. 22]
Jones Day Talks: EU's New Foreign Direct Investment Regulations Eye Specific Sectors
Day 17 of One Month to More Effective Compliance for Business Ventures- Corporate Controller and Business Ventures
Reporting entities under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) will soon be subject to a new requirement to report transactions suspected to be related to sanctions evasion to the...more
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
New Tri-Seal Compliance Note highlights sanctions and export control compliance expectations for non-U.S. persons. Three agencies overseeing U.S. trade law compliance provided an overview of where U.S. sanctions and export...more
Financial institutions and companies that are subject to oversight from the Office of Foreign Assets Control (OFAC) need to prioritize compliance. OFAC has become increasingly active in recent years, and it is devoting...more
For financial institutions and businesses that are subject to the oversight of the Office of Foreign Assets Control (OFAC), compliance needs to be a priority in 2023. OFAC is playing an increasingly active role in overseeing...more
OFAC continues its enforcement push. At the same time, OFAC is managing a complex, global set of sanctions against Russia. DOJ has promised to increase prosecution of global banks for sanctions violations....more
Key Points - On March 30, 2023, OFAC announced a settlement agreement with Wells Fargo for 124 apparent violations of three different sanctions programs (Iran, Syria and Sudan), all related to a legacy Wachovia Bank...more
Not that I am a glutton for punishment, but I always find enforcement actions to supply a number of valuable lessons learned. There are always instructive nuggets of information, opportunities missed, and root causes that...more
Since its last enforcement action against Banco Popular in late May, OFAC has been quiet on the enforcement front. Notwithstanding its silence, OFAC has been managing a robust and complex coordinated economic sanctions...more
OFAC is off to a quick start in 2022. After announcing its Airbnb enforcement action in the beginning of January, OFAC announced a settlement with Sojitz (Hong Kong) Limited, a Hong Kong, China-based company that engages in...more
Mashreqbank, based in Dubai, agreed to pay $100 million to the New York Department of Financial Services, the Federal Reserve, and the Office of Foreign Asset Control for violation of the now-repealed Sudan Sanctions...more
Global life sciences companies, research institutes, and universities face unique challenges when complying with U.S. and non-U.S. trade control laws, including complying with general and specific licenses authorizing...more
OFAC reported two new enforcement actions in the week between Christmas and New Year’s. The two new enforcement actions are interesting examples of sanctions enforcement, one of which involved the first against a digital...more
Deutsche Bank continues to have its problems – legal, compliance and reputational. Now, we can add OFAC sanctions compliance to the list of Deutsche Bank’s troubles....more
OFAC (Office of Foreign Asset Control) compliance applies to all US persons; including, all US citizens and permanent resident aliens regardless of their location, all persons and entities within the US, all US incorporated...more
OFAC is clearly sending a message about sanctions enforcement and compliance responsibilities. OFAC is aggressively seeking out new targets for enforcement. OFAC continues to focus on Iran, Cuba, Venezuela and North Korea,...more
OFAC’s new compliance framework includes a valuable section on common root causes of OFAC violations. OFAC has included this discussion to assist companies in designing, updating and amending their respective Sanctions...more
The upper house of the Russian Parliament, the Federation Council, approved a draft law on counter-sanctions (the “Counter-Sanctions Law”) on May 30, 2018, which appears to be identical to the version adopted by the Duma last...more