Part 1 of this series traced compliance’s early, clumsy attempts to capture data about its own programs, relying on hotline volumes and training completion rates that told you very little about whether misconduct was actually being deterred or caught. It also described the gap that emerged once regulators started expecting companies to actually use their data: the systems compliance functions had simply weren’t built to...

Compliance and data have been in a long relationship, and like most long relationships, it started awkwardly. This is the first of a three-part series tracing that relationship from its earliest, clumsiest days to where it’s headed with the arrival of AI-driven real-time monitoring. Part 1 covers how the profession first tried to capture data about its own programs and figure out whether any of...

October 28, 2026, 12 Noon EDT Sign Up HERE OFAC’s 2019 Framework for Compliance Commitments is still the foundational document every sanctions compliance program should be built on, but if your program hasn’t been updated since then, it no longer reflects how sanctions enforcement actually works today. Since 2023, the Department of Justice, the Department of Commerce’s Bureau of Industry and Security, and OFAC have...

Operation Economic Outcast has rightly drawn the most attention this month, and we’ve given it the two-part deep dive it deserves. But it wasn’t the only major economic-policy development in the same 30-day window. Three other stories are worth a quick roundup, because together they show just how many directions U.S. economic policy is pulling in at once right now: Syria, pursuing more sanctions relief...

Part 1 of this deep dive covered the two developments inside Operation Economic Outcast that hit compliance functions first: the sectoral expansion of Executive Order 13902 into aviation, digital assets, gold, shipping, and technology, and the sweeping suspension of general licenses that had authorized narrow, often noncommercial Iran-related activity. Part 2 turns to the other half of the campaign, and arguably the part that shows...

Treasury’s Operation Economic Outcast is the most consequential sanctions development of the year, and it deserves more than a passing mention in a broader roundup. This is Part 1 of a focused, two-part deep dive on the campaign. Here, we cover the two pieces of Operation Economic Outcast that create the most immediate, concrete compliance obligations: the expansion of Iran sectoral sanctions to five new...