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: Office of Foreign Assets Control (OFAC)
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 ...
Supply Chains Rattled by Hidden U.S. Sanctions Risks
A Case for Thorough Due Diligence A strong compliance program within your own company isn’t enough if your third-party suppliers ...
Managing the Risks of a U.S.-Iran Nuclear Deal Withdrawal
Practical Steps Non-U.S. Companies Can Take Now The international business community is watching intently to see whether the United States ...
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 ...
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 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 ...
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 ...
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 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 ...
Practical Steps for Compliance with NYDFS Regulation Part 504
5 Actions to Take Now With the New York State Department of Financial Services (“DFS”) Part 504 regulation’s first annual ...
