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The SEC (Sort of) Weighs In on How Personal Liability for Chief Compliance Officers May Undercut Effective Compliance Programs

December 14, 2020 | Compliance Risk + Compliance

Although regulators often seek to empower compliance officers within their institutions, a troubling question lingers as to whether regulators are undercutting this important message by simultaneously sending mixed or unrefined signals about when a Chief Compliance Officer should be held personally liable for the compliance failings of his or her firm. The director of the U.S. Securities and Exchange Commission’s Office of Compliance Inspections and Examinations recently urged investment firms to empower Chief Compliance Officers (CCOs), saying, “The CCO is … Read More

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