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
In today's digital landscape, sanctions enforcement has become a critical concern for Financial Institutions (FIs). The borderless nature of cyberspace can make it difficult to monitor and regulate activities that may breach...more
Recently, President Biden signed a foreign military support bill (H.R. 815) into law, which also encompassed the 21st Century Peace Through Strength Act (the Act), a legislative proposal introduced in the House containing...more
President Biden last month signed into law H.R. 815 (“National Security Supplemental” or “NSS”). The NSS—a package of national security and foreign aid appropriations, including for efforts in Israel, Ukraine, and the...more
While media reporting has predominantly focused on the provisions in the emergency foreign aid package that President Biden signed into law on April 24, 2024 that provides funding for Ukraine, Israel and Taiwan, House Foreign...more
Companies and their executives can reduce Department of Justice (DoJ), OFAC, and Commerce Department risks (and liability) by understanding and respecting the relationship between economic sanctions, voluntary...more
On FINCast Episode 39, Juan Zarate sits down with K2 Integrity’s Katya Hazard and Amir Fadavi to discuss the state of Russia-related sanctions and to explore what has worked and what may require further coordinated efforts to...more
The U.S. Government recently announced the largest round of sanctions against the Russian Federation (Russia) since the invasion of Ukraine two years ago. This multi-agency effort enacted over 500 sanctions against foreign...more
We previously have blogged on actions taken by the DOJ’s “Task Force KleptoCapture,” an interagency law enforcement task force with a mandate to target sanctioned Russian and pro-Russian oligarchs. While explicitly launched...more
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
The past few months have seen numerous high-profile enforcement actions highlighting an increasing trend, what Deputy Attorney General Lisa Monaco called “the biggest shift in corporate criminal enforcement that I’ve seen...more
Over the last several months, companies have become entangled in an increasingly complex web of new and expanded sanctions and export control restrictions related to Russia in response to its war on Ukraine. The current...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
The Office of Foreign Assets Control (OFAC) has oversight of financial transactions involving U.S. and foreign entities. It exercises this authority in several ways, including (i) through the administration of its various...more
July saw two noteworthy Russia enforcement actions. A Russian national was arrested in Estonia and extradited to the United States after being charged with conspiring to procure U.S.-origin technologies and ammunition on...more
On June 26, 2023, the Departments of Justice, Commerce, and Treasury issued a Tri-Seal Compliance Note that summarizes agency policy memoranda and existing regulations on voluntary self-disclosures (VSDs) of export controls...more
Companies that promptly self-disclose and remediate potential violations of administrative or criminal law may significantly mitigate liability. On July 26, 2023, the US Departments of Justice (DOJ), Commerce, and the...more
The U.S. Department of Justice (DOJ), Department of Commerce's Bureau of Industry and Security (BIS) and Department of the Treasury's Office of Foreign Assets Control (OFAC) on July 26, 2023, issued a Tri-Seal Compliance Note...more
The American Conference Institute is hosting their 17th Annual Flagship Conference on U.S. Economic Sanctions Enforcement and Compliance on April 25-26, 2023, in Washington! Don’t miss the opportunity to stay current with the...more
In line with the Biden administration’s declaration last year that anticorruption is a “core United States national security interest,” sanctions evasion enforcement rapidly has become a core priority for the Department of...more
On December 13, 2019, the U.S. Department of Justice (“DOJ”) issued a new policy for companies that voluntarily disclose potential criminal violations of U.S. sanctions and export control laws to the DOJ’s National Security...more
On 13 December 2019 the U.S. Department of Justice's (DOJ) National Security Division (NSD) announced the release of its long-anticipated and updated Export Control and Sanction Enforcement Policy for Business Organizations...more
Report on Supply Chain Compliance Volume 2, Number 20. (October 24, 2019) - Following statements from U.S. President Trump that led to the withdrawal of U.S. support from former Kurdish allies in northern Syria, Turkish...more
ANTICORRUPTION DEVELOPMENTS - $34 Million SEC Settlement for Legg Mason - On August 27, 2018, the Securities and Exchange Commission (SEC) announced that Legg Mason Inc. will pay more than $34 million to settle an...more
• 7-year denial order imposed against Chinese telecommunications equipment maker • Denial order strictly limits business with company • Action comes as U.S. imposes other trade restrictions on China On April 16, U.S....more