Tagged: OFAC sanctions

15 Jun, 2020

Treasury, State Department and Coast Guard Issue Advisory and Guidance on Maritime Industry Deceptive Shipping Practices

In response to an increase in deceptive shipping practices, on May 14, 2020, the State Department, Treasury Department and the Coast Guard issued a warning to the maritime industry, and those involved in the energy and metals sectors, concerning deceptive shipping practices used to evade sanctions. The focus of concerns appears to be actors seeking to circumvent sanctions against Iran, North Korea and Syria. The...

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

General

20 May, 2020

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)

Podcasts

11 May, 2020

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

General

23 Apr, 2020

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 [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”)...

Episode 130 — Practical Strategies for OFAC Sanctions Risk Assessments

Podcasts

8 Mar, 2020

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.

New BVD White Paper — What you need to know for sanctions compliance

Uncategorized

27 Nov, 2019

New BVD White Paper — What you need to know for sanctions compliance

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.

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

General

5 Aug, 2019

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 [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...

Catching Up with OFAC Sanctions Enforcement Actions

General

10 Jul, 2019

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)

General

16 Apr, 2019

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)

General

15 Apr, 2019

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...