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

The Volkov Law Group

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

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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

The Volkov Law Group

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

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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

The Volkov Law Group

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

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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)

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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

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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

The Volkov Law Group

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

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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

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

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