Tagged: sanctions compliance

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

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?”...

Episode 275 — Five Steps to Enhance Your Sanctions Compliance Program

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...

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

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...

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

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...

OFAC Enforcement Action: Double Check Your Screening Tools

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,...

Avoiding Compliance Overkill — Properly Assess and Manage Tangible Risks

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...

Ransomware and OFAC Sanctions Compliance

Ransomware and OFAC Sanctions Compliance

We have all read about the high-profile malicious cyber-attacks and ransomware demands and payments.  The Colonial Pipeline case demonstrated how responsive law enforcement can be in tracking down perpetrators and recovering ransom payments.  The Treasury Department’s Office of Foreign Asset Control (“OFAC”) has a vested interest in this enforcement arena.  On September 21, 2021, OFAC issued an updated ransomware advisory on the topic (“Updated Advisory”)....

Episode 81 — Update on OFAC Enforcement and Compliance Lessons Learned

OFAC is off to a fast start in 2019.  It has implemented enhanced Venezuela sanctions and designated PDVSA as a Specially Designated National, and brought four separate enforcement actions with important lessons learned for sanctions compliance. In this Episode, Michael Volkov reviews OFAC’s actions and outlines important sanctions compliance lessons learned.

Merging Trade Compliance and Ethics and Compliance Silos

Business operations can be riddled with inefficiencies.  It is easy to spot them inside a company.  The same rule applies to ethics and compliance programs.  Given a specific global business configuration, ethics and compliance programs have to be designed efficiently to support the business.  For some reason, a number of compliance programs have been built with two separate silos – one for trade compliance and...