Earlier this year the Treasury Department’s Office of Foreign Assets Control published A Framework for OFAC Compliance Commitments. It describes essential components of a sanctions compliance program (management commitment, risk assessment, internal controls, testing and auditing, and training).… Continue Reading
As long as U.S. federal law enforcement priorities remain the same, licensed cannabis operators are unlikely to be prosecuted if they are completely compliant with state laws.… Continue Reading
In March 2019, Transparency International Canada released a comprehensive report examining the ways in which Canada’s “lack of beneficial ownership transparency” contributes to money laundering (or “snow-washing”, as it’s known up North) within the Toronto real estate market.… Continue Reading
In our experience, cooperation with the due diligence process, and developing a deep understanding of the compliance expectations held by multinational companies, are competitive advantages.… Continue Reading
There has been a lot of discussion lately about the possible uses of artificial intelligence in anti-bribery compliance. Most commentators recognize that AI (and its more unassuming cousin, machine learning) won’t do away with current practices altogether.… Continue Reading
Due diligence in Russia has never been simple. Two recent developments make it more complicated. One makes business more transparent.… Continue Reading
I see it time and time again — third parties that would otherwise pass muster under a client’s due diligence process create their own red flags.
They push back on a local registration requirement.… Continue Reading
After reviewing the FCPA Blog’s post, “When do issuers disclose their FCPA problems?” which focused on the seven resolved FCPA cases during the first half of 2018, I also examined each of the enforcement actions with a specific goal of determining the impact of due diligence in these cases.… Continue Reading
We’re based in the United States, so how does the GDPR concern us?
GDPR’s Article 3(1) ties the GDPR’s territorial scope to being established in the EU, while Article 3(2)(a) extends the GDPR’s reach to those non-EU companies that offer products or services to individuals in the EU.… Continue Reading
It has been over three months since the EU General Data Protection Regulation (GDPR) went into effect. The sky hasn’t fallen, and we are still here.… Continue Reading