How to read the 2019 TRACE Risk Matrix
Robert Clark
December 5, 2019
We see it every year: A new edition of a corruption ranking is released, and the first thing people ask is which countries have moved up or down in ranking. It is common knowledge among compliance officers that a country’s position on such an index is just a starting point for a thorough corruption risk assessment, but there is still a danger that nuances will get lost in the high-level presentation of the data.… Continue Reading
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).… 
