If companies operated with perfect governance mechanisms and controls, they would all be ready for the coming sanctions enforcement storm.  However, that is not the corporate reality.  Even after several companies are the subjects of these aggressive enforcement actions, corporate boards, senior risk managers and senior executives will turn to the chief compliance officer and ask — “do we have an effective sanctions compliance program?”...

We have all read about the high-profile malicious cyber-attacks and ransomware demands and payments.  The Colonial Pipeline case demonstrated how responsive law enforcement can be in tracking down perpetrators and recovering ransom payments.  The Treasury Department’s Office of Foreign Asset Control (“OFAC”) has a vested interest in this enforcement arena.  On September 21, 2021, OFAC issued an updated ransomware advisory on the topic (“Updated Advisory”)....