Tagged: sanctions compliance

6 Oct, 2024

Episode 339 — The Four Sanctions Cases that Everyone Should Know

The Justice Department has repeated on several occasions that it intends to aggressively prosecute corporations for sanctions and export controls violations. The “New FCPA” is how the Justice Department characterizes its plan. To execute the strategy, DOJ has assigned 25 new prosecutors. This is the most important fact — unleashing 25 new prosecutors with the goal of bringing criminal cases against corporations and individuals will...

General

17 Jun, 2024

Is Your Sanctions Compliance Program Compliant? — A Quick Five-Question Quiz

Checklists can be handy — by simplifying and focusing on specific issues, a checklist can organize thinking and prioritize tasks. Here are five (5) questions that are fairly simple but revealing as to whether a company’s Sanctions Compliance Program (“SCP”) is effective. This is not an exhaustive list but it is my top 5. Question 1 — Does the Company conduct annual sanctions compliance training...

Podcasts

9 Jun, 2024

Episode 324 — Third-Party Risks and Sanctions Compliance

With the beginning of the era of the “New FCPA,” as coined by DOJ’s Deputy Attorney General Lisa Monaco, we now need to focus on third-party risk and sanctions enforcement. The law, the practice and the risks are important and not just the same as FCPA legal requirements. As we embark on a new criminal enforcement era surrounding sanctions violations, companies have to address this...

Uncategorized

20 May, 2024

The Same Old Song with a Different Meaning — Third-Party Risks and Sanctions Compliance (Part I of IV)

Sorry to start a four-part series with a reference to music from our long-ago past. The Four Tops sang the “Same Old Song, with a Different Meaning” (released in 1965 — Video Here). So, how does that relate to third-party risks? Well, bear with me here for a little. Legal and Compliance bloggers, compliance vendors, prognosticators, Compliance Podcasters, and everyone in the Paparazzi have written,...

Uncategorized

15 Feb, 2024

Preparing for the Storm — Effective Compliance in the New Sanctions Era (Part II of II)

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?”...

Podcasts

22 May, 2023

Episode 275 — Five Steps to Enhance Your Sanctions Compliance Program

Even with the current focus on sanctions compliance, many companies have done little to assess and enhance their existing sanctions compliance program. Instead, companies have stitched together a basic sanctions compliance program that centers on a screening tool and little beyond that. Such a limited program provides just a false comfort of compliance. Many companies are not even conducting the mandated basic requirement of annual...

General

12 Apr, 2023

Microsoft’s OFAC Settlement Underscores Important Remedial Measures (Part II of II)

Microsoft’s remedial steps provide important best-practices for companies facing similar risk factors in the global economy, especially for global software companies that rely on Internet-based operations. According to OFAC, Microsoft demonstrated a reckless disregard for U.S. sanctions by failing to identify that over a seven-year period, more than $12,000,000 worth of software and services were exported from the United States through Microsoft systems and servers...

selective focus of bitcoins on laptop computer

Podcasts

2 Nov, 2022

Episode 252 — Matt Stankiewicz on the Bittrex OFAC and FinCEN Enforcement Action: Cryptocurrency and AML and Sanctions Compliance

The Episode is available HERE. Matt Stankiewicz, a Partner at Volkov Law, is a leading industry expert on cryptocurrency. Bittrex, a leading cryptocurrency exchange, suffered twin enforcement actions for AML and Sanctions Compliance deficiencies. Matt takes a deep dive on the enforcement actions and outlines practical compliance steps that every cryptocurrency exchange should implement. The Episode is available HERE. Corruption Crime and Compliance is available...

General

29 Jul, 2022

OFAC Enforcement Action: Double Check Your Screening Tools

Jessica Sanderson, Partner at the Volkov Law Group, re-joins us for a posting on a recent OFAC enforcement action. Jessica can be reached at [email protected]. Some may dismiss OFAC’s recent announcement last week that it issued a Finding of Violation to MidFirst Bank for violations of the Weapons of Mass Destruction Proliferators sanctions regulations as insignificant because OFAC did not impose any civil monetary penalties,...

General

10 Jun, 2022

Avoiding Compliance Overkill — Properly Assess and Manage Tangible Risks

Alex Cotoia, Regulatory Manager and Compliance Consultant, rejoins us for a timely posting on compliance overkill in this era of aggressive sanctions enforcement. Alex can be reached at [email protected]. The uptick in recent sanctions activity caused in large part by the Russian Federation’s unprovoked and unilateral invasion of Ukraine has caused absolute pandemonium in many compliance circles. While the U.S. Department of Justice (and the...