
New BIS Export Compliance Guidance for Financial Institutions
The U.S. Bureau of Industry and Security recently published guidance for financial institutions on complying with strategic trade controls and discussing best practices, red flags, screening, and reporting. The latest guidance provides greater detail on due diligence and risk management to help financial institutions detect and deter emerging and evolving export controls evasion.

The Risks of De-Risking
Compliance officers are guardians at the gate: protecting their organization and the global financial system from abuse while also ensuring that licit funds flow undisturbed. This is a delicate balance, as global regulations continue to grow in complexity, prompting some financial institutions to de-risk from high-risk clients. What are high-risk clients? Must a bank cease its relationships with these clients?

AML Compliance for Small Businesses
Small businesses face the challenge of navigating the intricate landscape of anti-money laundering (AML) regulations. Despite the challenges posed by evolving global standards and limited resources, small businesses can use tailored strategies to fortify their compliance frameworks and thrive in a complex regulatory environment.

Adapting to Digital Assets Risks
In our recent webinar, "Mastering Compliance in Digital Assets through Multi-Tiered Defense Strategies," industry leaders examined the intricacies of digital asset compliance. Featuring a panel of industry experts including Andrew Rosenberg, Elizabeth Severinovskaya, and Catherine Woods, this blog post summarizes the key insights shared during the event.

Targeting Russia’s IT Dependencies
Delve into the recent determination issued by OFAC, which imposes significant additional restrictions on the provision to Russia of IT consultancy and design services as well as IT support and cloud-based services of enterprise management and design and manufacturing software. Multinational tech corporations, financial institutions, and other companies still operating in Russia will likely require licenses to continue operating there.

Understanding and Addressing Fraud and Corruption Risks
In our recent webinar, industry experts delved into the crucial topic of fraud and corruption risks. From seasoned professionals to anti-corruption activists, the webinar featured a panel of distinguished speakers: Steve Burgess, Nikki Kenyon, Chris Williams, and James Wasserstrom. This blog post aims to summarize the key points discussed during the session, equipping readers with the knowledge necessary to navigate these risks effectively.

OFAC’s Compliance Guidance in Action
The Treasury Department’s Office of Foreign Assets Control (OFAC) five years ago published its Framework for OFAC Compliance Commitments. This guidance remains the most comprehensive articulation of OFAC’s compliance expectations to date. Although it notably stopped short of mandating a sanctions compliance program (SCP), recent enforcement actions demonstrate the implications of not having an SCP in place.

Fake News vs. Real News – The Importance of Media in Due Diligence
We exist in an age when mass media outlets are criticized for bias and manipulation, and when foreign disinformation efforts further erode trust in traditional journalism. Confidence in media reports not just as a compliance tool, but also as reliable news sources is likely at near record lows as well. However, adverse media reports are a critical compliance tool that can serve as a springboard for more extensive due diligence research and can help identify potential indicators of sanctions evasion and other financial crimes.

Liberating Limits: OFAC Licenses
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The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) safeguards national security and helps advance U.S. foreign policy objectives by administering the U.S. sanctions regime. OFAC’s general and specific licenses serve as key mechanisms for authorizing and regulating certain transactions that would otherwise be prohibited under sanctions programs. The exceptions provided by licenses help businesses and individuals navigate international transactions without violating U.S. sanctions policies.

Stuck and Seized – Consequences of Forced Labor
Global economies are more interconnected than ever, and human rights abuses can have a profound impact on supply chains and disrupt the flow of goods. Recent deliveries of certain luxury vehicles, such as Porsches, Audis, and Bentleys have been delayed because a small component that links those vehicles with computer networks was produced by a Chinese company linked to forced labor and surveillance of Uyghur populations in China.