Episode 324 -- Third-Party Risks and Sanctions Compliance
FINCast Ep. 39 – State of Russia Sanctions Two Years After the Invasion
Understanding the Additional Risks When Making a Ransomware Payment
Looking The Other Way: Recent Cases Of AML And Sanctions Failings In Scandinavia
Episode 118 -- Update on OFAC Enforcement and Lessons Learned
On June 26, Treasury’s Office of Foreign Assets Control (OFAC) announced the settlement of an enforcement action against an Italian animation company that violated OFAC’s sanctions on North Korea. The enforcement action...more
While OFAC’s enforcement actions and guidance points to important steps exporters must take when relying on third-party distributors and other intermediaries, the “reason to know” and affirmative obligations to monitor resale...more
Life is always filled with surprises. Just when we thought 2023 was a “slow” FCPA enforcement year, DOJ and SEC announced a large enforcement action against SAP for approximately $220 million for FCPA violations in South...more
On December 13, 2023, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) announced an enforcement action against CoinList Markets LLC (“CoinList”) for violations of the Ukraine-/Russia-Related...more
When it comes to OFAC sanctions violations, honesty is the best policy. Promptly and voluntarily disclosing violations upon their discovery can pay serious dividends. ...more
Each year, the Office of Foreign Assets Control (OFAC) initiates several enforcement actions targeting companies, financial institutions, and individuals in the United States and abroad. These enforcement actions can present...more
Earlier this month, John Can Unsalan, the president of a steel-making company with ties to Russian oligarchs, pled guilty to one count of conspiracy to commit money laundering, based on financial transactions committed with...more
The past few weeks have not been kind to 3M. The company recently settled with the SEC for $6.5 million to resolve alleged FCPA violations related to its Chinese subsidiary’s dealings with Chinese state-owned healthcare...more
Construction Specialties, Inc. (“CSI”), a U.S. company specializing in the sale of building materials, agreed to pay $660,594 to settle its liability for three violations of OFAC’s sanctions on Iran. CSI’s illegal conduct...more
Company executives and stakeholders in charge of making decisions to insulate their business from legal liability by the Office of Foreign Assets Control (OFAC) at the U.S. Department of Treasury have a difficult choice to...more
The Office of Foreign Asset Control (“OFAC”) announced on June 20 that Swedbank Latvia AS (“Swedbank Latvia”), a subsidiary of Swedbank AB (“Swedbank AB”) headquartered in Riga, Latvia, agreed to pay $3,430,900 to settle its...more
Hosted by C5 Group, the European Forum on Global Economic Sanctions is recognized as Europe's Premier, longstanding gathering for financial institutions and global exporters. The industry across Europe is confronting an...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
On March 30, federal regulators announced that Wells Fargo Bank had entered into settlements in which it agreed to pay $97.8 million in fines for enabling sanctions violations between 2010 and 2015. In two separate...more
In our lifetime (however long or short), there is no way any company will ever match Wells Fargo for its record of misconduct, criminal and civil enforcement, and regulatory fines and penalties. No one, no way....more
Today’s alert—the third and final installment in our Sanctions 2022 Year in Review series—provides an overview of U.S. sanctions enforcement in 2022, including the key lessons learned from the enforcement actions issued by...more
Cryptocurrency companies are in trouble. Regulators are bearing down on crypto companies with the Eye of Sauron – pulling the crypto companies into their jurisdiction, prosecuting fraud cases, and aggressively prosecuting...more
On 24 September 2020, the U.S. Department of Treasury's Office of Foreign Asset Control (OFAC) announced a settlement with Keysight Technologies, Inc. (Keysight) for sanctions violations committed by its former subsidiary,...more
Addressing the Evolving Risks - Warren Buffett said that “only when the tide goes out do you discover who’s been swimming naked.” Buffett was not talking about compliance programs in a time of crisis, but his wisdom applies...more
Indictment Alleges that Bank and its Officers Used Front Companies to Evade Prohibitions on Iran’s Access to the U.S. Financial System - The U.S. Attorney for the Southern District of New York has charged Turkish state-owned...more
Over the past two years, prices for cryptocurrencies and other digital assets have experienced extreme gains and declines, while billions of dollars have been raised through Initial Coin Offerings (“ICOs”). In this dynamic...more