Day: March 3, 2020

Embargoed! Episode 2: Enforcement-palooza!

Post author By Miller & Chevalier
Post date March 3, 2020
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In this episode, we break down the most interesting enforcement actions of the past few months, including Exxon Mobil v. OFAC, the ITAR side of the Airbus DPA, and a series of recent OFAC settlements. Plus: The Lightning Round features bite-sized helpings of North Korea and Cuba with a side of Huawei.

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EMBARGOED! is not intended and cannot be relied on as legal advice; the content only reflects the thoughts and opinions of its hosts.
EMBARGOED! is intelligent talk about sanctions, export controls, and all things international trade for trade nerds and normal human beings alike, hosted by Miller & Chevalier Members Brian Fleming and Tim O’Toole. Each episode will feature deep thoughts and hot takes about the latest headline-grabbing developments in this area of the law, as well as some below-the-radar items to keep an eye on. Subscribe for new bi-weekly episodes so you don’t miss out!
Timestamps:
0:10 Introduction
The Rundown:
1:40 Exxon Mobil v. OFAC
16:53 Airbus Resolution of AECA/ITAR Charges
31:20 Park Strategies OFAC Settlement
36:05 Allianz/Chubb OFAC Settlement
40:42 Eagle Shipping/Burma OFAC Settlement
45:28 Lightning Round!:
45:49 Charges for DPRK Crypto Conference (U.S. v. Virgil Griffith)
49:02 Melia Hotels International/Gabriel Escarrer – U.S. Travel Ban
51:57 Extradition of Huawei CFO, Meng Wanzhou
56:05 Final Thoughts
***Stay sanctions free.***

31 Days to More Effective Compliance Programs

Welcome to ComTech

What will be the role of AI in compliance going forward? LawTech disrupted the legal profession and reshaped many areas of private practice. I believe there will is a nascent ComTech industry lurking down the road with multiple implications for the compliance function.Obviously, document review is one area where ComTech would be most useful. There are many companies which provide key word searches and these same concepts translate readily into the compliance world through massive database searches for key words, such as an ongoing review through email sweeps. There is yet another set of AI tools that can review contracts to see if any specific types of clauses are non-standard.
Soon compliance will be pushed more to the forefront in AML. AI will allow a more robust KYC approach. Another area where compliance is often left behind is in the arena of M&A. AI can help in this area. There are companies which have software that allows thousands of documents to be reviewed in the M&A context. A prime example of where AI can assist the compliance function is with third-parties in supply chain management.
There have always been technological innovations which help make compliance disciplines run more efficiently, more smoothly and more profitably. AI is simply another step in this line of technological developments. There is certainly no reason to be afraid of using it. Given the disruption which has impacted the legal profession through LawTech; disruption is not far behind in the compliance world through ComTech.
Three key takeaways:

AI has already disrupted the legal profession; the compliance profession will be next. ComTech will be the result.
Document review will be the first area of significant AI use in compliance.
Beware the limitations and disadvantages of ComTech.

For more information on how an independent monitor can help improve your company’s ethics and compliance program, visit this month’s sponsor Affiliated Monitors at www.affiliatedmonitors.com.

Tags ComTech

Innovation in Compliance

Coronavirus Risk Exposure with Ben Locwin

Post author By admin
Post date March 3, 2020
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Ben Locwin chats with Tom Fox about COVID-19 and the risk management issues associated with the disease in this week’s Innovation In Compliance show.

What is Coronavirus?
Ben says that coronaviruses have been around for a long time. During flu season, about 10% of patients with upper respiratory symptoms test positive for a type of coronavirus. The epicenter of the outbreak of this particular strain of the coronavirus is Wuhan, China, and there seems to be some correlation with the open air markets there. Though it’s suspected that the virus may have crossed from animals to humans, the nexus of the disease is unknown. He goes on to explain how the virus got its name and how it affects human cells.
Symptoms and Spread
Tom asks about the symptoms of the coronavirus (officially called COVID-19) and how it spreads. Symptoms, Ben says, include respiratory symptoms similar to a chest cold, such as coughing, having trouble breathing, and fever in more severe cases. In a relatively few cases, patients experience organ failure and septic shock and other serious issues, including death. Ben explains that this particular coronavirus spreads through aerosolized droplet infection: when an infected person coughs or sneezes in a public place, fine particulates of saliva and mucus are introduced into the air. Anyone there can inhale these particles and contract the disease. They can start experiencing symptoms within 2 to 14 days.
Common Sense Prevention
Ben comments on the stigma associated with COVID-19. While travel restrictions and other such responses make good sense, he points out that the outbreak of the virus is not yet a pandemic. If you’re experiencing upper respiratory symptoms, see your healthcare provider right away to have a test done. Your sample will be sent to the CDC for testing to determine if you have COVID-19. He advocates common sense prevention measures, the most important of which is hand hygiene: wash your hands regularly. When you’re in a public place try not to touch your eyes, nose or mouth and don’t touch food without washing your hands first. Face masks may also be useful. If you feel ill, stay at home, he advises.
Smart Risk Management Practices
Tom comments that many businesses are struggling with how to manage the risk associated with the disease. He asks Ben to give some advice in this regard. Ben responds that companies should take a smart approach. While you shouldn’t start panic buying and selling, and cease all travel, you should certainly limit non-essential travel whenever possible. “That’s just essentially limiting our exposure to risk,” he says. Tom adds that there are a number of modern communication tools that can be used instead of traveling to meetings. It’s sad that it takes situations like this to force companies to examine their business operations, Ben comments. However, by cutting out non-critical practices, businesses not only limit their risk exposure, but it also allows them to employ operational excellence.
Resources
CDC.gov/Coronavirus