Tagged: OFAC sanctions

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

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, and reflects the variety of ownership situations that occur. Given the overwhelming nature of the burden of a beneficial ownership risk mitigation strategy, we have to return to...

Episode 141 — Practical Approaches to Managing Beneficial Ownership Risks (Part II of II)

In a two-part series, Michael Volkov examines the continuing problem of identifying and mitigating beneficial ownership risks.  Money launderers and corrupt individuals continue to rely on corporate structures to disguise their ownership interests to further illicit schemes.  Companies have to develop strategies that practically address the risks without dedicating disproportionate resources to the problem. In the first episode, Michael Volkov discusses beneficial ownership risks and...

OFAC Releases Guidance on Sanctions Compliance During the Pandemic

Elizabeth Slim, Senior Consultant at The Volkov Law Group joins us for an important posting on OFAC sanctions compliance as a result of the pandemic.  Elizabeth can be reached at eslim@volkovlaw.com. It was only a matter of time before regulators and law enforcement recognized the impact that the pandemic has had on our country and our economy – The Office of Foreign Assets Control (“OFAC”)...

Episode 130 — Practical Strategies for OFAC Sanctions Risk Assessments

The Treasury Department’s Office of Foreign Asset Control (“OFAC”) is aggressively enforcing OFAC sanctions rules.  Last year, OFAC issued its Framework for Sanctions Compliance Programs, which includes a specific requirement for companies to conduct a “holistic” risk assessment. In this episode, Michael Volkov outlines practical strategies for conducting a sanctions risk assessment.

OFAC’s New §501.604 Reporting Requirement: A Small Change with a Big Impact

Matt Stankiewicz, Senior Associate, and Jessica Sanderson, Of Counsel, both at The Volkov Law Group, rejoin us for an interesting posting on a new OFAC reporting requirement. Matt can be contacted at mstankiewicz@volkovlaw.com, and Jessica can be contacted at jsanderson@volkovlaw.com. On June 21, 2019, OFAC changed its requirements for reporting on blocked or rejected transactions under 31 C.F.R. §501.604.  With little fanfare, the interim rule...

Catching Up with OFAC Sanctions Enforcement Actions

OFAC is clearly sending a message about sanctions enforcement and compliance responsibilities.  OFAC is aggressively seeking out new targets for enforcement.  OFAC continues to focus on Iran, Cuba, Venezuela and North Korea, aligning itself with current foreign policy objectives. Here is a brief outline of three recent enforcement actions: Western Union (HERE) — On June 7, 2019, OFAC released a settlement with Western Union under...

Standard Chartered Bank’s Continuing Culture Challenges and Sanctions Compliance (Part II of III)

Standard Chartered Bank certainly has its troubles.  You know a company is in trouble, however, when it breathes a sigh of relief after paying nearly $1.1 billion in fines and penalties and compares itself to BNP Paribas, the global French bank, which paid over $8 billion for pervasive US sanctions violations.  The Justice Department and OFAC have had a target-rich environment when reviewing global bank...

Standard Chartered Pays Over $1 Billion for Continuing Sanctions Violations (Part I of III)

Global banks are the poster children of sanctions violations and the importance of trade compliance.  At the top of the heap is Standard Chartered Bank. In a long-awaited resolution of a multi-year investigation, the Justice Department, the Treasury Department’s Office of Foreign Asset Control (OFAC), the New York District Attorney’s (DANY), the Federal Reserve, the New York State Department of Financial Services (DFS) and the...

OFAC Announces Two Sanctions Enforcement Settlements

What a difference a year makes — The Treasury Department’s Office of Foreign Asset Control (“OFAC”) announced two sanctions settlements in the beginning of 2019, a stark difference from 2018 when OFAC announced its first enforcement action in June 2018. ELF Cosmetics  On January 31, 2019, OFAC announced a $996,080 settlement with e.l.f. Cosmetics, Inc. (“ELF”), a California cosmetics company for violation of the North...