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RESULTS FOR: National Security

How Houses of Worship Can Best Prepare for The Worst

November 7, 2023 | Institutional Integrity National Security Risk + Compliance

Since my initial post on this subject in 2018, the world has once more undergone significant shifts, both on the global stage and within our own borders. As a result, I have taken a few moments to revisit my thoughts on this topic.

With the ongoing conflicts in the Middle East and the seemingly persistent gun violence in our own country, heightened concerns around the security of diverse faith communities have prompted us all to reevaluate and increase safety within … Read More

Focus on Foreign Banks’ Sanctions Compliance Programs in the U.S. and Globally
Upgrading and Empowering Compliance to Help Address National Security Risks 

January 10, 2023 | Financial Crime Consulting National Security Risk + Compliance

As the Russia – Ukraine war rages on, one outcome so far is clear:  the Western nations remain aligned and united to confront Russian aggression. The West’s synchronized, roll-out of economic and trade sanctions against Russia since February 2022 combined with their limited military support, demonstrate that the West’s tight, global coordination helps Ukraine courageously defend its nation and citizens. Importantly, coordinated alignment also protects the homeland and critical infrastructure of each Western nation, including that of the United States.… Read More

“Chipping” Away at the Right to Fundamental Research?

November 7, 2022 | Compliance National Security Risk + Compliance

New Export Control Regulations Must Be Examined to Ensure Protection of International Research Collaborations

U.S. government actions to enhance and protect U.S. technological innovation have been regularly featured in recent headlines. With the consistency of a drumbeat, press releases have announced new federal prosecutions, coordinated federal agency regulatory action, and bipartisan Congressional legislation designed to boost U.S. technology and protect it from malign foreign influences.

As a matter of fundamental U.S. policy, the federal government has made clear that promoting … Read More

Sanctions and The Supply Chain: Basic Steps to Protect Yourself

April 10, 2022 | Compliance National Security Risk + Compliance

With the Russian-Ukraine war’s ever-expanding sanctions landscape, the supply chain is even more complex than it already was, and enforcement risk is even higher given the broader array of U.S. federal and international agencies’ intent on strict compliance. It is increasingly necessary to regularly evaluate supply chain and trade operations to ensure companies are meeting their compliance expectations.  

For one, sanctions compliance is more than payments filtering and screening. It is also about export controls and licensing, cryptocurrency, and other Read More

When to Consider CFIUS Mitigation Requirements? Now!

September 17, 2020 | Compliance National Security

As my colleague Ken Mendelson noted, the watchword for ACI’s recent CFIUS conference was “mitigation.”  As a result of the new rules implementing the Foreign Investment Risk Review Modernization Act (“FIRRMA”), the number of deals requiring mitigation is likely to grow significantly.

The conference, however, focused mostly on the kinds of deals that would require mitigation.  The conference offered little detail regarding the specific mitigation measures that might be sufficient to get a transaction approved.  Those measures could … Read More

What to Prepare For and Expect With a CFIUS Monitor?

November 14, 2019 | Monitoring National Security

Given the recent expansion of transactions subject to review by the Committee on Foreign Investment in the United States (CFIUS), more foreign investments and acquisitions of US-based critical technology and data companies will need to be concerned about the government review.  Through the CFIUS review process, the government is attempting to mitigate US national security risks by foreign acquisition or investment in US-based companies which develop critical technologies or have access to sensitive US person data. Additionally, specific
Read More

Sanctions Compliance Requires More Than a Filter

December 7, 2017 | Compliance National Security 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 National Security 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

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