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Sanctions and The Supply Chain: Basic Steps to Protect Yourself

December 20, 2017 | Compliance Risk + Compliance

As the sanctions landscape becomes more complex and enforcement efforts expand across an array of federal agencies, it is increasingly necessary to regularly evaluate supply chain and trade operations to ensure companies are meeting their compliance expectations. The problem is compounded as the information technology landscape grows more robust and suppliers and buyers can be screened in real time, as well as the related parties within the transaction.

Sanctions compliance is predicated on strict liability, meaning no set of actions … Read More

Sanctions Compliance Requires More Than a Filter

December 7, 2017 | Compliance Risk + Compliance

As we detailed in our last post, sanctions compliance is becoming increasingly difficult because the amount of data companies ingest is increasing, and because both OFAC and prominent regulators such as the New York State Department of Financial Services and the Monetary Authority of Singapore (MAS) have clearly articulated that simply screening transactions is not sufficient.

The sanctions program that addresses the threat of North Korea, or the Democratic People’s Republic of Korea, effectively highlights the regulators’ expectations. … Read More

Sanctions in 2017: Where are we now

November 30, 2017 | Compliance Risk + Compliance

As we approach the one-year anniversary of the Trump Administration, it is important to take stock of what has changed within OFAC regulations. This past year has seen several major changes to sanctions regulations, including the removal of most sanctions against Sudan (except for some list based programs), rollback of certain travel authorizations under the Cuban sanctions program, and a much-increased focus on North Korea and Venezuela.

In many respects, OFAC has not significantly changed their pace of designations, … Read More

DEA Registrants Play a Vital Role in Preventing Diversion

September 14, 2017 | Compliance

With roughly 64,000 people dying from drug overdoses last year and with nearly one-third of those deaths involving prescription painkillers, the current administration has declared the opioid epidemic a “National Emergency.” Every day more than 1,000 people are treated in emergency departments across the country for misusing prescription opioids. It is estimated that almost 80% of heroin users first struggled with prescription opioid addiction. In this sense, prescription painkillers are walking users to heroin’s door, across that threshold … Read More

Hiring Refugees in Response to Trump Executive Order?

February 2, 2017 | Compliance Immigration + Border Services

In response to the Trump Administration’s Executive Order temporarily banning refugees and certain immigrants with origins from seven specific countries, several U.S. companies publicly declared their commitment to the hiring of refugees.  Specifically, Starbucks pledged to hire 10,000 refugees over the next five years and LinkedIn signaled their intent to speed up the expansion of LinkedIn’s “Welcome Talent” refugee support program. Other companies are considering following the lead of Starbucks and pledging to hire existing and newly arriving refugees.

For … Read More

Government Is Taking Action on Higher Education Immigration Fraud

September 25, 2012 | Compliance

If 2011 was the year where higher education immigration fraud was widely exposed, then 2012 is the year where the Government is taking action. And universities need to be prepared.

Though there has always been the potential for widespread immigration fraud in connection with higher education, a few instances of egregious fraud last year have brought the issue to the forefront.  In January of 2011, agents from Immigration and Customs Enforcement (“ICE”) raided Tri-Valley University in Pleasanton, California, on suspicions … Read More