News & Analysis as of

Third-Party Risk Office of Foreign Assets Control (OFAC)

The Volkov Law Group

“The New FCPA”: The Future Landscape of Sanctions Enforcement (Part II of IV)

The Volkov Law Group on

We are all familiar with — over and over — third-party risks and FCPA risks. It is drilled in our collective heads — third-party risks and bribery. Legal and compliance professionals have to learn and understand the ins...more

Thomas Fox - Compliance Evangelist

Corruption, Crime and Compliance: Third-Party Risks and Sanctions Compliance

With the beginning of the “New FCPA” era coined by DOJ’s Deputy Attorney General Lisa Monaco, we now need to focus on third-party risk and sanctions enforcement. The law, the practice, and the risks are important and not just...more

The Volkov Law Group

Supply Chain and Sanctions Compliance (Part III of IV)

The Volkov Law Group on

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

The Volkov Law Group

The Same Old Song with a Different Meaning — Third-Party Risks and Sanctions Compliance (Part I of IV)

The Volkov Law Group on

Sorry to start a four-part series with a reference to music from our long-ago past.  The Four Tops sang the “Same Old Song, with a Different Meaning” (released in 1965). So, how does that relate to third-party risks?  Well,...more

American Conference Institute (ACI)

[Event] FCPA & Anti-Corruption for the Life Sciences Industry - July 21st - 22nd, Boston, MA

ACI is excited to welcome you back in-person to the 14th Advanced Forum on FCPA & Anti-Corruption for the Life Sciences Industry, taking place on July 21–22, 2022 in Boston! Legal and compliance professionals from...more

NAVEX

Your Questions, Answered – Russia Sanctions: Impact on Your Third-Party Compliance Webinar

NAVEX on

Recently, NAVEX hosted a webinar featuring Michael Volkov and Jessica Sanders from the Volkov Law Group, titled Russia Sanctions: Impact on Your Third-Party Compliance. If you missed the webinar, visit the events page to...more

NAVEX

Staying Ahead of Sanctions – What You Need to Know to Maintain Compliance

NAVEX on

The threats posed by Russia to the Ukraine, and the worldwide implications, are deeply concerning and we denounce the invasion of the Ukraine by Russia and hope that this crisis can be resolved quickly through diplomacy. ...more

The Volkov Law Group

Practical Steps to Implement to Manage Third-Party Sanctions Risks (Part III of III)

The Volkov Law Group on

Facing the myriad third-party sanctions risks can be daunting.  Many global organizations rely on a network of third-party intermediaries that pose a variety of risks.  To mitigate those risks, companies have to implement...more

The Volkov Law Group

Managing Third-Party Sanctions Risks (Part I of III)

The Volkov Law Group on

If there is one issue that is repeated over and over (and over), it is third-party risks.  Over the last ten years, we have witnessed an explosion in anti-corruption enforcement around the world.  And with this enforcement...more

The Volkov Law Group

Keeping Track of Third Party Risks – Bribery and Sanctions

The Volkov Law Group on

We have heard it over and over, again and again – third-parties pose significant risks of bribery for all global businesses.  Almost every FCPA enforcement action includes some form of third-party misconduct.  The current...more

WilmerHale

OFAC Enforcement Actions Highlight Risks to Software Providers & MSBs

WilmerHale on

On April 29, 2021, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced two settlements of potential civil liability with two companies over their apparent violations of its regulations. The...more

K2 Integrity

Applying Expensive Lessons Learned: The Importance of an Effective Sanctions Compliance Program

K2 Integrity on

For international businesses, the costs of a weak sanctions compliance program can be steep, impacting both a company’s reputation and its bottom line. This year alone, the Treasury Department’s Office of Foreign Assets...more

The Volkov Law Group

Practical Risk-Based Ranking Strategies to Beneficial Ownership Issues (Part III of IV)

The Volkov Law Group on

At the outset, if you have a headache after reading my first two posts on the beneficial ownership issue, I apologize.  The issues twist and turn depending on whether the situation involves OFAC sanctions or corruption risks,...more

The Volkov Law Group

2019 OFAC Sanctions Enforcement Review (Part I of II)

The Volkov Law Group on

While DOJ had its biggest year in FCPA enforcement, OFAC quietly had a record year in enforcement.  OFAC collected approximately $1.28 billion (yes, with a B) in 26 separate enforcement actions.  That is quite an increase...more

The Volkov Law Group

OFAC Enforcement: The Epsilon Case and Third Party Risks

The Volkov Law Group on

The Department of Treasury’s Office of Foreign Asset Control (“OFAC”) recently announced the settlement of the Epsilon enforcement action. This case requires a theme song and there is none better than Trucking from Grateful...more

McGuireWoods LLP

White House Hostage Policy Leaves Risk on Table for Third Parties

McGuireWoods LLP on

Last month, the White House announced a change in its policy toward overseas hostage-takings of U.S. citizens. The new policy, accompanied by an Executive Order, aims to effect policy changes at home and overseas, including a...more

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