Hold onto your hats – while we are on the cusp of more FCPA enforcement actions, the Justice Department and OFAC are gearing up for real and significant sanctions enforcement actions.  The dye is cast, so here we go.  Deputy Attorney General Lisa Monaco was recently quoted stating that sanctions enforcement is the “new FCPA.” This is not so surprising given the global crisis caused...

Prosecutors and regulators are scouring their files for enforcement actions – criminal and civil – for violations of the 2014 Ukraine-Russia Sanctions Program.  The message being sent is clear – do not violate any sanctions against Russia, whether the initial round of restrictions in 2014 in response to Russia’s annexation of Crimea, or the broader sanctions recently implemented in response to Russia’s broader invasion of...

The continuing crisis in Ukraine has resulted in additional sanctions and export controls. It is hard to keep up with new developments each day. In recent steps, the United States has adopted a comprehensive set of export controls and implemented a ban on import of Russian oil, gas and coal. In this Episode, Michael Volkov reviews the recent changes to the Russia sanctions and export...

In response to Russia’s invasion of Ukraine territories, the so-called Donetsk and Luhansk People’s Republics, respectively, (hereinafter “DNR” and “LNR”), yesterday, on February 21, 2022, President Biden issued a new Executive Order targeting the DNR and LNR regions of Ukraine with comprehensive sanctions.[1] In practical effect, the new sanctions impose an embargo similar to that imposed against the Region of Crimea after Russia annexed the...

If there is one issue that is repeated over and over (and over), it is third-party risks.  Over the last ten years, we have witnessed an explosion in anti-corruption enforcement around the world.  And with this enforcement focus, it was inevitable that third-party risk would become one of the core areas for ethics and compliance programs. Indeed, the importance of third-party risk is underscored by...

On November 12, 2021, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”), pursuant to Executive Order 14046, Imposing Sanctions on Certain Persons With Respect to the Humanitarian and Human Rights Crisis in Ethiopia, issued sanctions against four entities and two individuals as part of a new sanctions program in Ethiopia. OFAC issued the  sanctions is in response to humanitarian and human rights...

Mashreqbank, based in Dubai, agreed to pay $100 million to the New York Department of Financial Services, the Federal Reserve, and the Office of Foreign Asset Control for violation of the now-repealed Sudan Sanctions Regulations.  The Sudan Sanctions Regulations were repealed on June 29, 2018. OFAC issued only a Finding of Violation, rather than impose a civil penalty, in light of Mashreqbank’s willingness to agree...

Matt Stankiewicz, Partner at The Volkov Law Group, joins us for a post on sanctions compliance in the cryptocurrency industry. Matt can be contacted at [email protected]. In early October, OFAC released a guidance brochure on sanctions compliance, specifically tailored for the cryptocurrency and virtual assets industry.  For seasoned compliance veterans, it ends up reading like a refresher course for sanctions compliance.  While the guidance was...