Today, we review a recent OFAC settlement over sanctions programs violations. The Kitchen looks into what the government found to be a mitigating and aggravating factor. Then we touch on the Framework for OFAC Compliance Commitments and align it with this enforcement action.
In this episode, the Kitchen looks at a recent OFAC settlement over Iran sanctions violations.
The Minsk agreements continue to go unimplemented, so the EU extends Russia sanctions again; OFAC grants an export license for certain petroleum products destined for Venezuela and the Kitchen is there to look into the details.
The Kitchen reminds all that the annual OFAC blocked property report deadline is coming up. We look at this process in more detail, including how and where to file and, importantly, what OFAC says should not be reported.
The Kitchen follows OFAC’s amendment to TSRA license FAQs and what modifications to the US HTS did the US ITC put in place.
This episodes looks at OFAC’s amendments to the narcotics and kingpin sanctions regulations. Next we will look at the DOD’s request for a public comment, the deadline and how to submit.
In today’s episode, we discuss the inherent challenges of operating a company in compliance with U.S. and international sanctions when the lists of sanctioned parties are a moving target.
Join us each week as we take a deep dive into the various forms of fraud across the world and discuss crime families, penny stock boiler rooms, international money launderers, narco-traffickers, oligarchs, dictators, war lords, kleptocrats and more.
Scott Moritz is a leading authority on white-collar crime, anti-corruption, and in the evaluation, design, remediation, implementation, and administration of corporate compliance programs, codes of conduct. He is also considered an authority in the establishment, training, and oversight of the investigative protocols carried out by financial intelligence, corporate security, and internal audit units.
Sylvia Surman returns in the Compliance Kitchen. In this episode, she discusses the update on some of OFAC’s recent SDN and sanctions activities. We will look at North Korea, Russia, Iran and Venezuela.
Mike’s favorite Marx Brothers movie Day at the Races is a fitting analogy for the race to effective compliance. Mike shares his favorite lines from the movie after which the discussion focuses on 3 Best Practices Compliance programs from the Criminal Division of the Department of Justice and OFAC.
Tom points out that each guidance document has a different focus depending on who released it. The Antitrust Guidance for example, is focused on criminal antitrust behavior: that is, the intention to defraud the market based on market fixing, cartel behavior or other intentional acts by more than one group or person. Each one of the documents gives greater insight to anti-corruption practitioners to incorporate into their compliance program.
There are elements that are common to all three documents. Mike says this emphasizes the importance of operationalizing your program to cut through the silos that exist in compliance. Compliance now has a reason to bring together all these elements into one comprehensive training program.
The Criminal Division of the Department of Justice asks for continuous monitoring of the compliance program. We need to take the data and loop it back into the compliance program to continually improve. Antitrust monitoring takes a statistical look at contract data over long periods of time to discover indications of cartel or price-fixing behavior. Anti-corruption monitoring shows the need for overall transaction monitoring from a compliance perspective so that red flags or anomalies are detected early on.
Once you have a database of contracts you can now have effective business analysis. You can analyze discounts given to customers over time and compare and contrast profit margins of contracts by geographical area or business unit. This is going to put the Compliance at the table for business discussions going forward. Compliance now becomes part of the business plan.
Resources OFAC Compliance documentCriminal Division Compliance documentAntitrust Division Compliance document
Welcome to the only roundtable podcast in compliance. In this episode, we begin a two-part episode where we consider the Trump Administration and Compliance, Part 1. This episode includes Sarah Hadden, Mike Volkov and Matt Kelly. Our next episode will feature Jay Rosen, Jonathan Armstrong and your host, Tom Fox.
The members of the Everything Compliance are:
The host and producer (and sometime panelist) of Everything Compliance is Tom Fox the Compliance Evangelist. Everything Compliance is a part of the Compliance Podcast Network.
