RESULTS FOR: National Security
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
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
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.
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