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OFAC has been busy and not so busy -- what do I mean? OFAC is administering a complex set of coordinated sanctions against Russia, in close coordination with the EU and the UK. This is not a simple matter. In addition to this close coordinating responsibility, the United States and its
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This blog post was co-authored by Daniela Melendez, an Associate with The Volkov Law Group. On June 14, 2024, U.S. Department of Commerce Assistant Secretary for Export Enforcement, Matthew Axelrod, officially issued an order activating the suspended portion of a civil penalty that was imposed on U.S-
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Organizations with operations in California are reminded of the upcoming July 1, 2024 deadline to comply with the provisions of S.B. 553—a bill that was signed into law by Governor Gavin Newsom on September 20, 2023, following swift passage by both houses of the California State Legislature earlier
Podcasts
Diligent recently released an important report -- Cybersecurity, audit, and the board: How does board oversight impact cybersecurity performance? Diligent's Report includes several key findings on the importance of Board oversight and its importance to cybersecurity performance. Dottie Schindlinger, Executive Director of Diligent Institute, the global corporate governance research
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On June 17, 2024, the U.S. Commodity Futures Trading Commission (CFTC) announced that trading giant Trafigura had agreed to pay a $55 million fine to settle charges of fraud and manipulation. The conduct at issue allegedly took place between 2014 and 2020, and included offenses such as trading on
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This blog post was co-authored by Daniela Melendez, an Associate with The Volkov Law Group. On May 30, 2024, following passage by the European Parliament in late April, the European Council officially adopted a set of rules that modernizes and harmonizes money laundering and terrorist financing (“AML/CFT”) regulations
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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
Podcasts
The new compliance cottage industry surrounds artificial intelligence. We are at such an early stage of AI development -- companies are still figuring out how they can employ the technology. Some industries, such as financial institutions, however, have been using AI for fraud detection and other issues. I expect financial institutions
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We all know what a "core" sanctions violation looks like. The heartland of such misconduct has been described on numerous occasions in OFAC enforcement actions and settlements. In this environment, however, companies have to be aware of conduct that may still violate the law but is not necessarily
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In this new era of aggressive sanctions enforcement, companies have to understand the red lines that define where criminal and civil enforcement risk increase. In contrast to the history of FCPA enforcement, DOJ and OFAC have provided helpful guidance to alert companies where risks are likely to increase. Sanctions enforcement
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On June 3, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) announced the resolution of an administrative enforcement action brought against Airbus DS Government Solutions (“Airbus DSGS”)—a subsidiary of defense giant Airbus U.S. Space & Defense—for multiple violations of longstanding antiboycott
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LRN's research consistently paints a picture that every board member, senior executive and middle manager should view -- corporate culture is an organization's most valuable intangible asset and is a significant determinant of success in the marketplace. Corporate leaders know how to mouth the words to express