Companies have to implement a sanctions compliance program (SCP). The Treasury Department Office of Foreign Asset Control’s sanctions guidance issued in May 2019 is an extraordinary document and includes numerous prescriptive requirements. Companies ignore the SCP Guidance at their peril. The Treasury Department’s Office of Foreign Asset Control (OFAC) has a robust and mature enforcement program. Over the last few years, OFAC has successfully expanded its enforcement...
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- COSO ERM and Cloud Computing August 19, 2021
- Governance, Fraud, and Corporate Culture: Sorting Through a Complicated Relationship April 15, 2021
- Environmental, Social, and Governance or ESG April 14, 2021
- Internal Controls – A Process to Help Ensure Internal Controls are Designed Consistently and Appropriately April 8, 2021
- Ethics and Compliance: Active Board Involvement Is a Must April 5, 2021