Tagged: sanctions

7 Apr, 2021

Biden Administration Ramping Up Anti-Corruption Effort

The Biden Administration is taking over the reins of government with vigor and focus. The Department of Justice, the Treasury Department, the State Department and the Commerce Department are expected to coordinate closely in an important objective – international anti-corruption efforts. What will this mean? DOJ will increase its focus on FCPA enforcement, Anti-Kleptocracy cases, Anti-Money Laundering, International Trade Sanctions; The Treasury Department’s Office of...

General

9 Apr, 2020

Videoconferencing and Export Controls

Janet Longo, Regulatory Compliance Analyst at The Volkov Law Group, joins us for a posting on videoconferencing and compliance export controls. Janet can be reached at jlongo@volkovlaw.com. As the Covid-19 virus is proliferating, so is the practice of conducting business through videoconferencing from home. While many commentators have discussed the serious data privacy and security problems associated with video conferencing, we’ve been thinking about the...

General

18 Dec, 2018

OFAC Announces Russia Sanctions Settlement with Software Company

The Department of Treasury’s Office of Foreign Asset Control (“OFAC”) recently announced a settlement against Cobham Holdings (and its former subsidiary Aeroflex/Metelics, Inc. (“Metelics”, a software company) for $87,507 for violations of OFAC’s Ukraine-Russia sanctions program. (OFAC announcement here). Metelics violated the Ukraine-Russia sanctions program on three occasions between July 31, 2014 and January 15, 2015, by selling telecommunications and computer software (3,400 switch limiters;...

General

21 Oct, 2018

NAVEX Global Releases 2018 Third-Party Risk Benchmark Report

NAVEX Global has issued its Third-PartyBenchmark Report. (HERE). The NAVEX Global Report contains important insights and data concerning ethics and compliance programs and third-party risk management strategies. I was pleased to assist NAVEX Global in preparing the 2018 Benchmark Report. Knowing how to appropriately define, screen and monitor your third parties is essential to minimizing risk. New industry benchmarks, along with the expert guidance provided in...

General

17 Jan, 2018

Financial Institutions Are Playing Catch-Up in AML and Sanctions Compliance

Compliance officers are a much more collaborative group of professionals than lawyers. Compliance officers share information with colleagues about compliance experiences, best practices and strategies. The compliance industry benefits from this sharing of information. On occasion, however, this sharing of a company’s performance in one area can lead to unfair judgments by a recipient of the information. For example, one company may conduct an in-depth...

General

29 Sep, 2016

Dig a Little Deeper: The Importance of Beneficial Ownership

Companies interact with a large number of entities in the outside world – customers, third party intermediaries and vendors and suppliers to name the most significant ones. These relationships are the lifeblood of a company. In today’s world, companies have to know with whom they are dealing – not just the name of the company, not just the officers of the company, but the natural...

General

21 Aug, 2016

Anti-Corruption, Sanctions and Export and Import Risks

Forgive me for overusing the term “convergence” but when the shoe fits, I say “wear it.” If you are managing corporate risks and are responsible for securing export licenses, ensuring that you are complying with OFAC sanctions requirements, interacting with customs and immigration officials around the globe, and conducting third party due diligence to onboard a new agent or distributor, there is no question that...

General

19 Apr, 2016

Fokker: No Judicial Oversight of Deferred Prosecution Agreements

The D.C. Circuit dealt a blow last week to judicial attempts to exercise supervision over Justice Department negotiated Deferred Prosecution Agreements. In United States v. Fokker (Here), the Court answered the question in a resounding affirmation of the authority of prosecutors to resolve criminal cases and exercise discretion in charging decisions. In the end, the court’s decision was not a great surprise but the strength...

General

25 Jan, 2016

Beneficial Ownership: Sanctions and FCPA Compliance

Financial institutions have been pushing back hard on FinCEN’s proposal to require banks, investment banks and other financial institutions to identify beneficial owners of account holders. As time goes on the impact of FinCEN’s proposal is diminishing. Why? In general, businesses have other reasons to secure beneficial ownership information. One key concern is sanctions compliance. To the extent an account holder engages in international transactions,...

General

17 Jan, 2016

The Changes to Iran Sanctions and Compliance Challenges

Putting aside the politics surrounding the Iran Nuclear Deal, the exchange of prisoners and other hot button political issues surrounding Implementation Day and the change in US-Iran relations, the new Iran sanctions create a new set of challenges for trade compliance officers. Talk about a headache — all you have to do is look at the new guidance, Frequently Asked Questions, and related documentation (Here)....