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
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
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
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
The Treasury Department’s Offices of Foreign Assets Control (“OFAC”) continues its enforcement run in 2021, and added yet another tech company to its list of targets....more
On June 3 of this year, the Biden Administration made plain its commitment to fighting corruption around the world, releasing a document identifying the fight against corruption “as an economic and national security priority”...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 continues to aggressively enforce its sanctions programs. In its latest enforcement action, OFAC agreed with Société Internationale de Télécommunications Aéronautiques SCRL (“SITA”), a Swiss telecom company, to an...more
This is the sixth in our start-of-year series examining important trends in white collar law and investigations in the coming year. Our previous entry discussed enforcement by the Massachusetts Attorney General’s Office in...more
Apollo Aviation Group, now Carlyle Aviation Partners, agreed to pay OFAC $210,600 for 12 violations of the Sudanese Sanctions Program. Carlyle acquired Apollo in December 2018, and Carlyle was not involved in the...more
OFAC's aggressive enforcement program continues. Recently, OFAC announced settlements with Apollo Aviation and Apple. Both of these cases underscore the importance of enhancing OFAC compliance programs. In this Episode,...more
OFAC’s aggressive enforcement program continues to bear fruit. The latest settlement involved GE and three of its subsidiaries, which agreed to pay $2.7 million for 289 alleged violations of the Cuba Sanctions Program. So...more
On June 21, 2019, OFAC changed its requirements for reporting on blocked or rejected transactions under 31 C.F.R. §501.604. With little fanfare, the interim rule published in the Federal Register greatly expands the...more
On of the most well known of all criminal procedural rights was established by the US Supreme Court on this day in 1966, when the Court handed down its Miranda v. Arizona decision. It established the legal principle that all...more
There is no question that OFAC continues to dominate the enforcement landscape this year. OFAC has provided plenty of warning and notice to global companies, especially those in the manufacturing and industrial sectors....more
The Department of Treasury’s Office of Foreign Asset Control (“OFAC”) recently announced a settlement against Cobham Holdings (and its former subsidiary Aeroflex/Metelics, Inc. (“Metelics”, a software company) for $87,507 for...more
On July 5, 2017, Bureau Van Dijk, a sponsor of my blog, conducted a webinar on the importance of beneficial ownership information to corporate compliance functions....more