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Companies have had over one year to review and implement a sanctions compliance guidance program. This last year, however, has been difficult (to say the least) given the COVID-19 pandemic. Companies have had unusual challenges. OFAC recognized the impact of COVID-19 when it issued guidance in April 2020
Podcasts
Amazon joins the exclusive club of high-tech OFAC violators. Last year, Apple settled with OFAC for sanctions violations. This year, we can add Amazon to the list of OFAC violators. On July 8, 2020, Amazon settled with OFAC for $134,523 for violations of multiple OFAC sanctions programs. Amazon’
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The Antitrust Division’s recent indictment of the boiler chicken executives provided an important reminder to compliance officers on the importance of an effective antitrust compliance program. With last year’s Guidance on Antitrust Compliance, DOJ has provided a roadmap for compliance officers to design and implement an effective compliance
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In response to an increase in deceptive shipping practices, on May 14, 2020, the State Department, Treasury Department and the Coast Guard issued a warning to the maritime industry, and those involved in the energy and metals sectors, concerning deceptive shipping practices used to evade sanctions. The focus of concerns
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At the outset, if you have a headache after reading my first two posts on the beneficial ownership issue, I apologize. The issues twist and turn depending on whether the situation involves OFAC sanctions or corruption risks, and reflects the variety of ownership situations that occur. Given the overwhelming nature
Podcasts
In a two-part series, Michael Volkov examines the continuing problem of identifying and mitigating beneficial ownership risks. Money launderers and corrupt individuals continue to rely on corporate structures to disguise their ownership interests to further illicit schemes. Companies have to develop strategies that practically address the risks without dedicating
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Elizabeth Slim, Senior Consultant at The Volkov Law Group joins us for an important posting on OFAC sanctions compliance as a result of the pandemic. Elizabeth can be reached at eslim@volkovlaw.com. It was only a matter of time before regulators and law enforcement recognized the impact that the
Podcasts
The Treasury Department's Office of Foreign Asset Control ("OFAC") is aggressively enforcing OFAC sanctions rules. Last year, OFAC issued its Framework for Sanctions Compliance Programs, which includes a specific requirement for companies to conduct a "holistic" risk assessment. In this episode, Michael Volkov outlines
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Bureau van Dijk, a Moodys Analytics Company, recently released a new white paper, What you need to know about sanctions compliance. You can download the white paper here. I was pleased to contribute to the white paper and hope you find it helpful.
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Matt Stankiewicz, Senior Associate, and Jessica Sanderson, Of Counsel, both at The Volkov Law Group, rejoin us for an interesting posting on a new OFAC reporting requirement. Matt can be contacted at mstankiewicz@volkovlaw.com, and Jessica can be contacted at jsanderson@volkovlaw.com. On June 21, 2019, OFAC changed
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OFAC is clearly sending a message about sanctions enforcement and compliance responsibilities. OFAC is aggressively seeking out new targets for enforcement. OFAC continues to focus on Iran, Cuba, Venezuela and North Korea, aligning itself with current foreign policy objectives. Here is a brief outline of three recent enforcement actions: Western
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Standard Chartered Bank certainly has its troubles. You know a company is in trouble, however, when it breathes a sigh of relief after paying nearly $1.1 billion in fines and penalties and compares itself to BNP Paribas, the global French bank, which paid over $8 billion for pervasive US