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...

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 [email protected]. 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”)...

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.

Bureau van Dijk, a Moodys Analytics Company, recently released a new white paper, What you need to know about sanctions compliance. You can download the white paper here. I was pleased to contribute to the white paper and hope you find it helpful.

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 [email protected], and Jessica can be contacted at [email protected]. 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...

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...