Skip to content

Editors

Harry Cassin
Publisher and Editor

Andy Spalding
Senior Editor

Jessica Tillipman
Senior Editor

Richard L. Cassin
Editor at Large

Elizabeth K. Spahn
Editor Emeritus

Cody Worthington
Contributing Editor

Julie DiMauro
Contributing Editor

Thomas Fox
Contributing Editor

Marc Alain Bohn
Contributing Editor

Bill Waite
Contributing Editor

Shruti J. Shah
Contributing Editor

Russell A. Stamets
Contributing Editor

Richard Bistrong
Contributing Editor

Eric Carlson
Contributing Editor

Bill Steinman
Contributing Editor

What did WeWork teach us about ‘private-company’ compliance?

As the leader of a private company, WeWork’s former CEO Adam Neumann clearly wasn’t subject to strong expense reporting requirements or conflicts of interest processes — he threw extravagant parties, routinely hired his family members and close friends, and engaged in numerous related-party transactions.… Continue Reading

These ‘mistakes’ are behind most OFAC violations

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

OFAC adds 17 Saudis to Magnitsky sanctions list

Murdered Saudi journalist Jamal KhashoggiThe U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated three Saudi officials and 14 members of a hit team for their role in murdering Washington Post contributing columnist Jamal Khashoggi.… Continue Reading

Due diligence on the oligarchs: Predicting OFAC’s next move

Oleg DeripaskaWith the proliferation of OFAC designations of Russian businesspeople, trying to predict whether or not someone will be designated as a Specially Designated National (SDN) has become an important part of third party due diligence on Russian business partners. … Continue Reading

Selva Ozelli: How should cyptocurrency bribes be valued?

At the federal level in the United States, cryptocurrencies have a lot of regulators — FinCEN, OFAC,  the IRS, the Commodity Futures Trading Commission (CFTC), and the SEC among them. 

These regulators characterize cryptocurrencies respectively as money, property, commodities, and a security.   … Continue Reading

Lindsay Columbo: What fuzzy logic can (and can’t) do for due diligence

In 2015 OFAC penalized the National Bank of Pakistan for apparent violations of U.S. sanctions programs resulting from a software failure. According to OFAC, the bank’s New York branch processed wire transfers after its sanction screening tool failed to detect the name of the account — LC Air company Kyrgyztransavia — as belonging to Kyrgyz Trans Avia, a blocked entity.Continue Reading