Category: Archive

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Berkshire Hathaway Settlement Highlights Compliance Risk for Large Firms

Click here for PDF Berkshire Hathaway’s (“BH”) $4.1 million settlement in October 2020 with the US Treasury’s Office of Foreign Assets Control (OFAC) for apparent violations of Iran sanctions by its Turkish subsidiary highlights the importance of not only ensuring a robust sanctions compliance program that incorporates strict oversight of affiliates, subsidiaries, and counterparties, but …

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Generali Settlement Highlights Travel Industry Risk

Click here for PDF On September 25, 2020, Generali Global Assistance, Inc (“Generali”) entered into an agreement with the US Treasury’s Office of Foreign Assets Control (OFAC) to pay $5,864,860 for 2,593 apparent violations of Cuba sanctions totaling $285,760. Generali attempted to circumvent the US financial system and evade sanctions in its transactions with Cuban …

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Firms Face Increased Reputational Risk for Corporate Responsibility Failures

Click here for PDF Executive Summary   Recently, Walt Disney Studios and metals and mining corporation Rio Tinto found themselves embroiled in scandals stemming from significant environmental, social, and corporate governance (ESG) failures, highlighting the need for firms to conduct research into potential reputational risks—in addition to due diligence and compliance checks—before engaging in business …

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US Government Issues North Korea Ballistic Missile Procurement Advisory

Click here for PDF. On 1 September 2020, the US Treasury’s Office of Foreign Assets Control (OFAC) issued a joint advisory with the State Department’s Bureau of International Security and Nonproliferation and the Commerce Department’s Bureau of Industry and Security to inform US and foreign entities about North Korea’s (DPRK) ballistic missile procurement activities. The …

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Turkey Facing Sanctions Threats; Enhanced Due Diligence Recommended

Click here for PDF As US relations with Turkey fray, we assess that US legislators will work to impose sanctions on Turkish defense companies and financial institutions that support their involvement in weapons systems purchases from America’s adversaries. These efforts will face an uphill climb in Washington because the White House and the Republican-controlled Senate …

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OFAC Adds Hong Kong Designations

Click here for PDF On 7 August 2020, the Treasury Department’s Office of Foreign Assets Control (OFAC) designated 11 top Chinese officials and their allies in Hong Kong, including Chief Executive Carrie Lam, pursuant to Executive Order 13936 over their role in undermining the autonomy of the former UK colony. We anticipate that Bernard Charnwut …

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UK Office of Financial Sanctions Implementation Issues Maritime Advisory

Click here for PDF The UK Office of Financial Sanctions Implementation (OFSI) has issued a Maritime Advisory to supplement its general guidance document that was updated in July, 2020, outlining companies’ obligations under the UK’s sanctions regime, as well as OFSI’s approach to licensing and compliance issues. OFSI’s Maritime Advisory in many ways mirrors guidance …

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OFAC’s Amazon Penalty Highlights Need for Human Touch

On July 8, 2020, Treasury’s Office of Foreign Assets Control (OFAC) settled with with Amazon.com, Inc. over the company’s potential civil liability for its likely violations of US sanctions. The tech giant has agreed to pay $134,523 to settle allegations that it provided goods and services to individuals in Crimea, Syria, and Iran.

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Xinjiang Supply Chain Business Advisory Warns US Firms of Regulatory and Reputational Risks

Click here for PDF On July 1, 2020, the Departments of Commerce, Homeland Security, State, and Treasury published an advisory describing the “risks and considerations for businesses with supply chain exposure to entities engaged in forced labor and other human rights abuses in Xinjiang.” The advisory—an effort to help mitigate reputational, economic, legal, and other …

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Miami Attorney Acts as Gatekeeper for Maduro Regime Insiders

Executive Summary A Miami attorney almost certainly acts as a facilitator for entities and individuals with ties to Venezuela’s Maduro regime. The individual has not been investigated for or charged with knowingly participating in or facilitating unlawful activity, likely because he removes himself as registered agent or attorney of record before these individuals and entities …

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