Economic sanctions enforcement is a fast-rising risk for global companies. For many years, the Treasury Department’s Office of Foreign Asset Control (“OFAC”) focused primarily on financial institutions. Over the last ten years, OFAC has stretched its enforcement eyes towards software, manufacturing, telecommunications and technology companies. With this growth in sanctions enforcement, OFAC has embraced an aggressive view of third-party risks. Like the FCPA, under OFAC’s regime, third parties...

Choose to be optimistic. It feels better.” – Dalai Lama Forgive me for my optimism.  It is the only way to live a meaningful life.  Or as some would say – being a pessimist is too much of a burden.  We begin a New Year — and I am optimistic. To turn the corner here on relevance, ethics and compliance professionals, are by definition, optimists. Give...

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...

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...

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 [email protected]. 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...

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;...