The Justice Insiders Podcast - The Ever-Expanding Net: Corporate Compliance in an Era of Increasing Trade Sanctions and Restrictions
Understanding the Additional Risks When Making a Ransomware Payment
WorldSmart: The Extraordinary Sanctions Against Russia - What Happens Next?
BSA, OFAC, KYC, and CIP – What do they mean to me? [More with McGlinchey, Ep. 29]
Compliance Perspectives: Sanctions, Data and Vetting Third Parties
FINCast Ep. 19 - The DPRK Sanctions Program
Episode 118 -- Update on OFAC Enforcement and Lessons Learned
On October 31, 2024, the U.S. Treasury Department's Office of Foreign Assets Control (OFAC) issued scenario-based guidance specific to the maritime shipping industry....more
On 9 October 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) published its first ever unilateral guidance specifically addressed to financial institutions (FIs). The Guidance to Financial...more
The Justice Department has repeated on several occasions that it intends to aggressively prosecute corporations for sanctions and export controls violations. The “New FCPA” is how the Justice Department characterizes its...more
July was a big month for compliance with a handful of reports and recommendations on due diligence and best practices concerning forced labor, export controls, sanctions from DHS, BIS, and OFAC. The below updates also...more
Sanctions and export controls were the top items of interest in June. On the compliance side, OFAC and the BIS announced new sanctions and export controls on Russia and Belarus. The new measures target individuals and...more
May saw the long-awaited release of the USTR’s Section 301 review. USTR confirmed that the Trump-era tariffs will remain in place, and raised those tariffs by another $18 billion on manufacturing, critical minerals, solar...more
During the first quarter of 2024, there were significant developments in the U.S. sanctions framework. This report summarizes the key developments and provides links to the relevant sources....more
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
OFAC is getting ready for a big year. While managing a comprehensive set of sanctions against the Russian Federation in response to its Invasion of Ukraine, OFAC has demonstrated its ability to maintain aggressive...more
The various and elusive tactics used by Russia to evade global sanctions and export controls have grown increasingly sophisticated over the last several months, putting the onus on multinational entities to become equally...more
For U.S. businesses, sanctions compliance has never been more challenging or more important. The U.S. has responded to Russia’s invasion of Ukraine with a broad range of sanctions targeting the Russian government, its...more
Throughout December, the United States, European Union, and United Kingdom adopted a series of new sanctions packages against Russia that are expansive and multilayered and pose additional compliance challenges. The new...more
In our prior update (published November 29), we provided the first five steps in our twelve-step program for international compliance. These steps are intended to help companies identify international regulatory risk inherent...more
Record penalties for violations of U.S. regulations governing international conduct and transactions illustrate the risk of costly enforcement actions facing multinational companies. Yet, many multinational companies lack...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
On September 22, 2023, the U.S. Department of Treasury Office of Foreign Assets Control (“OFAC”) issued its “Reminder to file your 2023 annual report of Blocked Property,” noting that entities or persons subject to the...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
Each quarter, we send many of our clients a quarterly trade compliance update, highlighting important developments over the last few months and summarizing key points for important sanctions programs. ...more
The rise of ransomware attacks has prompted the international community to explore a range of approaches to deter these attacks, including the use of sanctions, the further development and instantiation of norms governing...more
On April 6, 2023, the Department of Treasury Office of Foreign Assets Control (“OFAC”) and the Department of Commerce Bureau of Industry and Security (“BIS”) announced a settlement with Microsoft Corporation (“Microsoft”) and...more
As we have noted on numerous occasions, the U.S. Russia Sanctions and Export Control Program is unprecedented and a compliance challenge for all organizations. In another unprecedented action, the Justice Department and the...more
Approximately one year ago, in the immediate wake of Russia’s full-scale invasion of Ukraine, the United States (U.S.), United Kingdom (UK), and European Union (EU) launched a global sanctions campaign against Russia that...more
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
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
The UAE is the Middle East’s leading financial center and a global hub for trade, particularly in gold and precious metals. This large presence within the global financial system makes it a target for financial crime,...more