Checklists can be handy — by simplifying and focusing on specific issues, a checklist can organize thinking and prioritize tasks. Here are five (5) questions that are fairly simple but revealing as to whether a company’s Sanctions Compliance Program (“SCP”) is effective. This is not an exhaustive list but it is my top 5. Question 1 — Does the Company conduct annual sanctions compliance training...
In another significant step notifying global businesses of the new realities – companies are about to face aggressive coordinated prosecutions for sanctions and export control violations. The last piece in launching this new effort was the announcement of a joint voluntary disclosure program to ensure alignment among the agencies for civil and criminal enforcement of such violations. The Joint Compliance Note (“JCN”) urges companies to...
Alex Cotoia, Regulatory Manager at The Volkov Law Group, rejoins us for a posting on new guidance concerning Iranian unmanned aerial vehicles (“UAVs”). Alex can be reached at [email protected]. In a relatively rare move for four (4) Cabinet-level Departments, the U.S. Departments of Commerce, Justice, State and Treasury issued an advisory notice on June 9, 2023, aimed specifically at reminding industry of their obligations vis-a-vis...
