Day: March 17, 2020

EMBARGOED! Episode 3: Reading the Sanctions Tea Leaves

Post author By Miller & Chevalier
Post date March 17, 2020
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In this episode, hosts Brian Fleming and Tim O’Toole summon all of their prognostication powers to take a closer look at the Halkbank case, the future of U.S. sanctions against Iran, Venezuela, and North Korea, and the latest OFAC enforcement action. Plus: The Lightning Round features more Huawei (of course) and deep thoughts on the meaning of rejection (at least as defined, or not, by OFAC).

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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

Superforecasting

Imagine that as a CCO, you could create a team which might well dramatically improve your company’s compliance and risk forecasting ability, but to do so you would be required to expose just how unreliable the professional corporate forecasters have been. Could you do so and, more importantly, would you do so? Most generally this is the predictive capability that organizations have used. However, the new “superforecasting” movement, led by Philip E. Tetlock and others, has been gaining strength to help improve this capability.
The concepts around superforecasting came of age after the intelligence failures leading up to the Iraq War. This led to the founding of the Good Judgment Project, which had as a key component a multi-year predictive tournament, which was a series of gaming exercises pitting amateurs against professional intelligence analysts. The results of the Good Judgment Project. Today, I explain its applicability to compliance.
Three key takeaways:

Imagine you could create a team which might well dramatically improve your company’s compliance and risk forecasting ability.
It is essential to track the prediction outcomes and provide timely feedback to improve forecasting going forward.
Like any innovation, there must be a commitment from management on moving forward.

Tags Superforecasting

Innovation in Compliance

Customizing Proactive Compliance Monitoring with Jordan Domash

Post author By admin
Post date March 17, 2020
No Comments on Customizing Proactive Compliance Monitoring with Jordan Domash

Jordan Domash, General Manager at Relativity, is this week’s guest on the Innovation In Compliance show. He chats with Tom Fox about his company’s Relativity Trace solution, and how to use it in your compliance program.

A Proactive Approach
Jordan describes Relativity Trace as “…a communication, surveillance, and monitoring tool built on top of the Relativity platform for compliance purposes.” Tom asks him how it can be used in a proactive approach to compliance. He responds that when potential issues need to be investigated, Relativity Trace can sift through millions of files using machine learning, search, and human review to detect risk proactively. He points out that their out of the box policies can detect issues such as bribery, corruption, and price-fixing. In addition, companies can configure their own rules based on the compliance risks that are relevant to their business. When there is a potential compliance violation, the system will proactively generate alerts.
Relativity One
Tom asks Jordan to talk about another discovery solution Relativity offers, namely Relativity One. Jordan responds that Relativity One is the SAAS version of Relativity: it’s an e-discovery tool that can help you search and review content as part of an investigation, and then create reports. Each activity that happens in Relativity leaves a permanent audit trail, which ensures that the review process is defensible.
Document Security
After you self-disclose, the first thing the government asks is if your documents are secure, Tom comments. He asks Jordan how their solution handles security. Jordan describes the tools in Relativity Trace that ensure data security, including the legal hold tool. He reiterates that every action in Relativity is audited. “It’s all exportable. It’s all filterable. It’s all searchable. So it’s very possible to take a look at your audit trail and find the relevant behavior or the whole history of the matter, the investigation or the combined process, and share that with regulators.”
Tom asks how the solution deals with false positives, in answer to which Jordan outlines various measures built into Relativity that handle this problem. “It’s not just the Machine Learning that can help you reduce false positives right away, but it’s a full collection of tools that Relativity Trace gives you to go through your process quickly… and identify risks in your business,” Jordan comments.
Resources
Relativity Trace