All Things Investigations: Episode 30 - The Convergence of ABC, AML and Export Controls with Mike Huneke and Jan Dunin-Wasowicz
BSA, OFAC, KYC, and CIP – What do they mean to me? [More with McGlinchey, Ep. 29]
The first quarter of 2024 saw numerous developments on the export control front. This report summarizes the key developments and provides links to the relevant Federal Register notices and/or agency announcements....more
With the ever-increasing use of sanctions as a foreign policy tool (or weapon), sanctions compliance has taken on greater importance than ever. Moreover, as countries increase extraterritorial applications of their sanctions,...more
In the context of COVID-19, there are significant challenges involved in conducting due diligence: hard-copy documents are inaccessible, in-person meetings have moved online, and on-site visits may be impossible....more
I am in a multipart series on the Framework for OFAC Compliance Commitments (Framework). Every compliance professional of any stripe needs to read, understand and implement some of the key concepts of the Framework into your...more
You are the chief legal officer of a U.S. company. Your CEO walks into your office and announces that your company is about to conclude its first international sale. In addition, the company has just appointed distributors in...more
Since 2005, a series of very large non-U.S. banks — including ABN AMRO, Credit Suisse and ING — have paid significant penalties to U.S. authorities for processing funds transfers through the United States related to business...more