News and commentary about white-collar crime, enforcement, and compliance
Harry Cassin
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Andy Spalding
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Jessica Tillipman
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Bill Steinman
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Richard L. Cassin
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Elizabeth K. Spahn
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Cody Worthington
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Julie DiMauro
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Thomas Fox
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Marc Alain Bohn
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Bill Waite
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Russell A. Stamets
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Richard Bistrong
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Eric Carlson
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OFAC — the Treasury Department’s Office of Foreign Assets Control — publishes a running log of its sanctions enforcement activity against corporations. The DOJ and SEC do the same with the FCPA.
Although there are numerous parallels between sanctions enforcement and the FCPA, which I talked about last time, there are also significant differences. Let’s look at a few of those.
Self-Contained v.
In the past couple of months, sanction list screening has become one of the most critical compliance tasks. A single question has triggered much of the change: “Are my business partners and other third parties I deal with really sanctioned?”… Continue Reading
The Evaluation of Corporate Compliance Programs, first published five years ago, is now one of the most important compliance tools, not only for the DOJ prosecutors it’s addressed to, but also for compliance professionals outside government.… Continue Reading
Regimes for combating human rights abuses are gaining momentum, examples of which include the European Parliament resolution of March 10, 2021 recommending to the EU Commission the introduction of corporate due diligence and corporate accountability, and Germany’s Supply Chain Due Diligence Act (Lieferkettensorgfaltspflichtengesetz) of June 11, 2021.… Continue Reading
All compliance officers have special skills that set them apart from everyone else. They’re “subject matter experts” in ethics and compliance. That makes them unique. But within the ranks of compliance officers, who are the generalists and specialists?… Continue Reading
The U.S. Treasury Department’s Office of Foreign Assets Control said Wednesday it fined Berkshire Hathaway, Inc. $4.2 million after a subsidiary based in Turkey knowingly violated OFAC’s sanctions against Iran.… Continue Reading
Rarely a month passes without the U.S. “maximum pressure” campaign against the likes of Venezuela and Iran making headlines, but a lesser-known, yet similarly robust, sanctions offensive is being quietly waged by the Treasury’s Office for Foreign Assets Control.… Continue Reading
The Treasury Department’s Office of Foreign Assets Control issued a new advisory Thursday warning banks, insurance companies, negotiators and others about sanctions risks from helping victims make ransomware payments.… Continue Reading
On September 2, the United States designated the chief prosecutor from the International Criminal Court (ICC), as well as an ICC senior official, to the Specially Designated Nationals (SDN) and Blocked Persons List, the first exercise of sanctions under a June 11 executive order targeting the ICC due to its ongoing investigation of U.S.… Continue Reading
The Treasury Department’s Office of Foreign Assets Control imposed sanctions on 11 Hong Kong officials Friday, including the territory’s head of state, for “undermining Hong Kong’s autonomy and restricting the freedom of expression or assembly of the citizens of Hong Kong.”… Continue Reading
The U.S. Treasury Department’s Office of Foreign Assets Control used a settlement agreement Thursday to set out management’s role in creating and running an effective sanctions compliance program.… Continue Reading