Admit It – Your Compliance Program is Not Really “Effective”
“Happy talk” amounts to empty words absent a frank, honest discussion of the issues. Michael Volkov explains one reason why ...
Tag: OFAC
Welcome to the OFAC Compliance Framework
It's the most detailed statement to-date of OFAC’s views on the best practices that companies should follow to ensure compliance ...
Why Hong Kong is China’s Sanctions Hot Spot
Clifford Chance’s Wendy Wysong and Nick Turner discuss the sanctions risks looming in Hong Kong and what companies operating there ...
The Antitrust Division Guidance on an Effective Compliance Program
As the third in a triumvirate of releases on compliance programs, the DOJ's Antitrust Division released its antitrust compliance program ...
5 Common Weaknesses in OFAC Sanctions Compliance Programs
If your business activities take place in the U.S., you need to be doing OFAC screening. Michael Volkov offers five ...
Catching Up with OFAC Sanctions Enforcement Actions
Michael Volkov highlights three sanctions-related enforcement actions all breaking in the last six weeks – and two of which involved ...
OFAC Puts Asian Companies on Notice with “Compliance Framework”
The Clifford Chance team covers OFAC’s recently published “Framework for OFAC Compliance Commitments,” with a particular focus on how the ...
OFAC Enforcement Action Underscores Russia Sectoral Sanctions
Michael Volkov details the settlement between the U.S. OFAC and Haverly Systems, which was found to be in violation of ...
U.S. Tests New Sanctions Strategies on Russia, Venezuela
Clifford Chance’s Wendy Wysong and Nick Turner discuss recent sanctions leveled by the U.S. against Russian and Venezuelan corporations and ...
OFAC Announces 2 Sanctions Enforcement Settlements
What a difference a year makes — The Treasury Department’s Office of Foreign Asset Control (OFAC) announced two sanctions settlements ...
OFAC Enforcement: The Epsilon Case and Third-Party Risks
What the Decision on Epsilon's Sanctions Violations Means for Companies Michael Volkov discusses Epsilon's sanctions violations, the resulting "reason to ...
A Compliance Crisis in North Korea
How to Avoid Sanctions Risks A recent advisory issued by the U.S. Department of the Treasury’s Office of Foreign Assets ...
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