Tag: Russia Sanctions

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Daily Compliance News

March 15, 2022 the Compliance is Complicated Edition


In today’s edition of Daily Compliance News:

  • Compliance is complicated in the shadow of Russia. (WSJ)
  • Tencent looking at big AML fine in China.  (WSJ)
  • Corruption and death in Brazil’s imperial city. (FT)
  • Russia and managing political risk. (FCPA Blog)
Categories
Compliance Kitchen

EU Sanctions on Russia Update

EU sanctions state-owned outlets RT/Russia Today and Sputnik broadcast; BIS bans export of luxury goods to Russia, Belarus.

Categories
Compliance Kitchen

Singapore readies a sanctions package against Russia.


Singapore readies a sanctions package against Russia.

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This Week in FCPA

Episode 293 – the Ukraine Hangs On edition


As Ukraine hangs on from the Russian invasion, Jay is on assignment so fan fav Kristy Grant-Hart joins this week as a co-host with Tom to look at some of the week’s top compliance and ethics stories from the impact of the Ukrainian crisis in the Ukraine Hangs On edition. 
Stories

  1. What Russia invasion means for companies and compliance. Tom with a series in the FCPA Compliance and Ethics Blog. Matt Kelly in Radical Compliance.
  2. Dick Cassin says sanctions may lead to more corruption in the FCPA Blog.
  3. Jaclyn Jaeger looks at supply chain disruption and issues in Compliance Week (sub req’d)
  4. Matthew Murray asks if Putin invaded Ukraine to advance corruption, in GAB.
  5. Chasing oligarchs’ money, from the Washington Post.
  6. The Swiss approach to Ukraine crisis. Mark Pieth in Risk and Compliance Europe.
  7. Mike Volkov focuses on new and evolving sanctions, in Corruption Crime and Compliance.
  8. Economic nationalism and corporate governance. Martin Geller, in Harvard Law School Forum on Corporate Governance.
  9. Illicit finance and High-value art. Sullivan & Cromwell lawyers in Compliance and Enforcement.
  10. The invasion and cybersecurity. Jonathan Armstrong in Cordery Compliance.

Podcasts and More

  1. In March on The Compliance Life, I visit with Audrey Harris, Managing Director at AMI, formerly CCO at BHP. In Part 1, she discusses her academic background and early professional career.
  2. On the FCPA Compliance Report, Tom has a 2-part series with Trade Compliance guru Matt Silverman on the full extent of possible Russia sanctions (Part 1) and the corporate response you need to make (Part 2).
  3. Tom and Loren Steffy look energy issues and fallout from the Russian invasion in Greetings and Felicitations.
  4. Tom and Matt Kelly take a deep dive into the compliance weeds about the Russian invasion on Compliance into the Weeds.
  5. Silvia Surman devotes the entire week to Russian trade sanctions and economic issues in The Compliance Kitchen.
  6. Tom celebrates Texas Independence Day and the anniversary of the Alamo in a podcast with Don Frazier, Executive Director of the Texas Institute at Schreiner University on The Hill Country Podcast.

Tom Fox is the Voice of Compliance and can be reached at tfox@tfoxlaw.com. Kristy Grant-Hart is Compliance Kristy and can be reached at kgranthart@sparkcompliance.com.

Categories
Daily Compliance News

March 3, 2022 the 1MDB Deal? Edition


In today’s edition of Daily Compliance News:
·      Did Trump Administration cut deal on 1MDB scandal? (Reuters)
·      Former Illinois House Speaker indicted over ComEd scandal.   (The Hill)
·      Oligarchs in US sanctions sights. (WaPo)
·      Will sanctions drive Russia into crypto? (NYT)

Categories
Compliance Into the Weeds

Compliance Issues from the Russia Invasion of Ukraine


Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. This week, Matt and Tom take a somewhat somber view on the Russia invasion of Ukraine. Some of the issues we consider:

  • Discussion of sanctions.
  • What do sanctions mean for US, UK and EU countries?
  • How companies should think about doing business in Russia going forward.
  • What about energy production and consumption?
  • US company employees in Ukraine and Russia.
  • The role of China in a potential resolution.

Resources
Tom in the FCPA Compliance and Ethics Blog
Matt in Radical Compliance

Categories
Compliance Kitchen

Sanctions on so-called Donetsk and Luhansk People’s Republics


This week the Compliance Kitchen is looking at sanctions levied on Russia because of its invasion of Ukraine. Today, the US introduces Comprehensive Sanctions on so-called Donetsk and Luhansk People’s Republics.

Categories
Daily Compliance News

February 26, 2022 the Distributors Settle Edition


In today’s edition of Daily Compliance News:

  • Distributors settle with states on opioid claims. (NYT)
  • More disclosures for shorts?  (WSJ)
  • Abramovich linked to Putin regime. (DailyMail)
  • SEC looking at Goldman employee communications. (Reuters)
Categories
This Week in FCPA

Episode 292 – the Russia Invades edition


As Russia invades Ukraine, Tom and Jay settle in and are back looking at some of the week’s top compliance and ethics stories this week in the Russia Invades edition.
Stories

  1. What Russia invasion could mean for corporate governance. Michael Peregrine in Forbes.com. What do sanctions mean for US companies? Jaclyn Jaeger in Compliance Week (sub req’d)
  2. Why is subculture audits so critical? Vera Cherepanova explains in the FCPA Blog.
  3. KT Corp. settles FCPA enforcement action. Tom (FCPA Compliance and Ethics Blog) and Mike Volkov (Corruption Crime and Compliance) both have 3-part series. Matt Kelly’s take in Radical Compliance. Tom and Matt in Compliance into the Weeds.
  4. National Cryptocurrency Enforcement Team and what it means. Kathleen McDermott and Mark Krotoski in CCI. David Smagalla in WSJ Risk and Compliance Journal.
  5. How Credit Suisse facilitated crime, corruption, and dictators. Jessie Drucker and Ben Hubbard in the New York Times.
  6. Why diversity on investigation teams matters. Karin Portlock and Jabari Julien in Compliance and Enforcement.
  7. Could small-cap directors & officers could face ESG liability. Lawrence Heim in practicalESG.
  8. Global trends in corporate governance for 2022. Richard Fields, Rusty O’Kelley III, and Laura Sanderson, in Harvard Law School Forum on Corporate Governance.  
  9. Roger Ng trial in danger of collapse due to prosecution ‘inexcusable error .’Stewart Bishop in Law360. (sub req’d)
  10. Using the FCPA to fight the demand side of bribery. Matthew Stephenson in GAB. 

Podcasts and More

  1. In February on The Compliance Life, I visited with Ellen Smith, a former Director of Trade Compliance who recently started her consulting firm. In Part 1, she discussed her academic background and early professional career. In Part 2, Ellen discussed her move in-house. In Part 3, Ellen discusses being a part of the Compliance Dream Team at Weatherford. In Part 4, Ellen moves into the world of consulting.
  2. On the FCPA Compliance Report, Tom began a 2-part series with Trade Compliance guru Matt Silverman on possible Russia sanction (Part 1) and the corporate response (Part 2). Part 2 posts Monday, February 28.
  3. CCI releases a new e-book from Mike Volkov, “Compliance Culture Revolution .”Available free from CCI.
  4. Gwen Hassan has a special 2-part pod series on Hidden Traffic with Jeff Bond, from the Global Fund to End Modern Slavery, on the impact of climate change on modern slavery. Part 1 and Part 2.
  5. Are you a Star Wars fan? How about an uber-Geek? You will love the 5-part series on Science of Star Wars in the Greeting and Felicitations podcast series on the Compliance Podcast Network if you are either or both. In this series, Tom visits astrophysicist Dr. Ben Locwin on the following topics: Episode 1-Traveling in Hyperspace, Episode 2-Fighting with a Light Saber, Episode 3-Mechanical Prosthetics, Episode 4-Cyborgs, and Robots and Episode 5- Death Star. It is a ton of fun, and you will love it.

Tom Fox is the Voice of Compliance and can be reached at tfox@tfoxlaw.com. Jay Rosen is Mr. Monitor and can be reached at jrosen@affiliatedmonitors.com.

Categories
Blog

Potential Russia Sanctions and Corporate Response

This week on the FCPA Compliance Report, I began a two-part podcast series on the potential U.S. sanctions if Russia invades Ukraine and what can be done to prepare. The guest and subject matter expert for the podcast was Matt Silverman, Director of Trade Compliance at VIAVI. Now that Russia has invaded Ukraine, I thought the need was even greater to get this information out. This blog post highlights Matt’s thoughts on both topics. I urge to listen to the two podcasts in their entirety to understand what sanctions might be levied and how you can help your company prepare a response.

  • What are the potential U.S. sanctions if Russia invades Ukraine?
    1. Impose a comprehensive or near-complete embargo of Russia.
    2. Impose additional sectoral sanctions on certain Russian industries.
    3. Prohibit exports of certain items or technology to Russia.
    4. Designate Russian entities under the Foreign Direct Product Rule.
    5. Add specific Russian entities or individuals to OFAC’s Specially Designated Nationals and Blocked Persons List (“SDN”).
    6. Prohibit Russian entities from accessing the U.S. financial system/using U.S. dollars and/or sanctioning foreign banks that conduct transactions with sanctioned Russian entities.
    7. Prohibit U.S. persons or entities from investing in Russian companies, requiring divestment, and/or sanctioning foreign entities that buy Russian government bonds.
    8. Impose “secondary sanctions” on entities or individuals that conduct certain transactions with Russia.
    9. Freeze Russian assets located in the U.S.
    10. Ban U.S. financial assistance to Russian entities.
    11. Withhold U.S. aid to any organizations that assist Russia.
    12. Prohibit imports and/or impose high tariffs on specific Russian imports.
    13. S. State-Level Sanctions: States may enact laws that prohibit business with, or require divestment of shares in, firms that conduct certain transactions with Russia.
  • What can be done to prepare?
    • First, ascertain your exposure and consider how some or all of these actions would impact your business.
    • Check your sanctions screening policies and procedures and check your customers and business partners in real time against global sanctions lists.
    • Identify all of your contracts with Russian entities or individuals and review your contracts for compliance with law clauses, notice clauses, and termination provisions.
    • Know your customer.
    • Identify what, if any, items, or technology you are exporting to Russia and any transactions with Russian entities that have ongoing or continuing obligations.
    • Take a look at your supply chain to avoid business interruption.
    • Identify whether you have any outstanding debts from Russian entities or individuals, and, if so, promptly purse collection activities.
    • Identify any procurement or manufacturing activities for goods intended for Russia and consider whether you can safely postpone or delay those activities, especially if you are dealing with specially designed or non-fungible goods (without breaching any contracts or risking failure to meet deadlines).

Resources
Matt Silverman on the potential U.S. sanctions if Russia invades Ukraine. (Part 1)
Matt Silverman on What can be done to prepare your company. (Part 2)