Categories
Compliance Into the Weeds

Microsoft OFAC Enforcement Action

The award-winning, Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. In this episode, join Tom and Matt as they delve into Microsoft’s recent sanctions enforcement action with OFAC. They explore what went wrong and how to avoid costly compliance failures, from potential red flags to reseller relationships. But it’s not all doom and gloom as they discuss how Microsoft implemented three lines of defense model for sanctions compliance, setting a benchmark for the industry. With Tom and Matt going into the weeds on the importance of centralization and persistent screening technology, this podcast is a must-listen for any compliance officer looking to stay ahead of the curve. Tune in now to find out more!” 

Key Highlights 

·      Sanctions compliance case involving Microsoft

·      Microsoft’s Sanctions Compliance Model

·      Microsoft’s Sanctions Compliance Program Remediation

·      Sanctions Compliance and OFAC Guidance

·      Impact of Russia invasion on Microsoft operations

 Notable Quote:

“It’s well worth giving the case a good look. So it was, I thought, a great lesson on resellers and the way the hardware and software industry did business.”?

 Resources

Matt  on LinkedIn

Matt on Radical Compliance

Tom

Instagram

Facebook

YouTube

Twitter

LinkedIn

Categories
Compliance Kitchen

Compliance Kitchen – Navigating OFAC’s Latest Guidance on Russia’s Metals and Mining Sector

The Compliance Kitchen, hosted by Silvia Surman, is a podcast that examines and evaluates the changing legal framework of international compliance. In this episode, Silvia examines OFAC’s brand new determination concerning the metals and mining sector of the Russian Khanate. She provides listeners with an FAQ about the determination and explains that it authorizes certain energy-related transactions or if General Licensed 6C only authorizes those activities. Silvia further elaborates that the license authorizes transactions related to the production, manufacturing, sale, transport, or provision of medicine and medical devices. Tune into Compliance Kitchen to stay updated with the evolving legal framework of international compliance.

Notable Quotes

1. “This February 24 determination authorizes sanctions on any person that the government determines to operate or have operated in the metals and mining sector of the Russian economy.”

2. “OFAC does not intend to target persons for operating in this metals and mining sectors where the provision of their goods and services is solely for safety and care of personnel protection of human life, prevention of accidents or injuries, maintenance, necessary repairs, to avoid significant or environmental damage or activities that are related to environmental mitigation or remediation.”

3. “Non-US persons generally do not risk exposure to US blocking sanctions. Under executive order 14024 for engaging in transactions with black persons, including in the metals and mining sector where those transactions would not require a license if a US person were engaging in the transactions.”

4. “Non-US persons generally do not risk exposure to US blocking sanctions if they engage in transactions in the mining and metals sector. If General License 8F would normally authorize such transactions as in Frank. That 1 authorizes certain energy-related transactions or if General would only authorize those activities Licensed 6C. That license authorizes certain transactions related to the production, manufacturing, sale, transport, or provision of medicine, medical devices, including certain industrial isotopes used in nuclear medicine.”

Categories
Compliance Kitchen

Compliance Kitchen on OFAC and DOJ Developments

The Compliance Kitchen returns with a wrap-up of the week’s top trade and economic sanction issues. In today’s episode, Silvia Surman looks at OFAC issues Russia-related sanctions licenses and allows for limited marine activities on SDN vessels; DOJ obtains a guilty plea for EAR violations due to unlicensed exports of chemicals to a Chinese SOE listed on the Entity List.

Categories
Daily Compliance News

September 2, 2022 the Wife Too Edition

In today’s edition of Daily Compliance News:

  • Healthcare is a dangerous business in Russia. (WSJ)
  • Big tech is moving production out of China. (NYT)
  • Najib’s wife gets 10 years for her role in 1MBD. (Al Jazeera)
  • JPMorgan German offices searched in trading scandal investigation. (Reuters)
Categories
Life with GDPR

Boris Johnson Announces Resignation


Jonathan Armstrong and Tom Fox return for another episode of Life with GDPR. In this episode, we discuss British Prime Minister Boris Johnson’s recent announcement that he will be resigning as British PM when his successor is announced. Some of the highlights  include:

  1. Reasons for the resignation.
  2. Candidates for the PM role going forward.
  3. Key compliance and related issues for the new PM going forward.
  4. Lessons learned from the Pincher Affair and the BoJo resignation.

Resources
For more information on the issues raised in this podcast, check out the Cordery Compliance News Section. For more information on Cordery Compliance, go to their website here. Also, check out the GDPR Navigator, one of the top resources for GDPR Compliance, by clicking here.

Categories
Putin's Oil Heist

Putin’s Oil Heist Episode 6: Connecting the Dots


“I believe that Yukos was Putin’s first foray into trying to test the West… and the West fell flat on their faces – they did absolutely nothing to help the Western shareholders in Yukos.” The lack of response from the West during the Yukos Affair encouraged Putin’s tyranny. Putin’s Oil Heist is an insider’s account of the Yukos Affair. In this final episode, Loren Steffy draws a line from the 2022 invasion of Ukraine back to the expropriation of Yukos in the early 2000s, with first-person accounts from former Chief Financial Treasurer, Bruce Misamore.

Hear him talk about:

  • The West’s inaction. Yukos, in its bid to embrace Western standards of capitalism in the hopes of gaining a New York Stock Exchange listing, hired Misamore and other American shareholders. But when Putin’s government trumped up tax charges and used them to seize the entire company without compensating those shareholders, the US government did nothing. Misamore claims they could have made government-to-government claims on behalf of the shareholders that were harmed. The West’s failure to act became a pattern in the following years, which only emboldened Putin.
  • Putin’s grand plans. Had the invasion of Ukraine gone the way he wanted, it’s likely that Putin wouldn’t have stopped there, Misamore contends. Putin regrets the fall of the Soviet Union, and there have been hints throughout his presidency that suggest his intention to revive it. His next logical target, after Ukraine, would have been Moldova, and then the rest of Georgia. The resistance of the Ukranians seems to have halted Putin’s thirst for conquest.
  • The Russian people. The innocent citizens of Russia are not responsible for the actions of their government. Though Putin has improved their standard of living to keep up his popularity, they could easily be talked into going the other way. However, they’re scared and docile, behavior instilled by centuries of violent history, and they fear the dire consequences of rebellion. In addition, the government’s crackdown on independent media, prevents the people from getting an accurate view of the war in Ukraine.
  • How the Yukos Affair influenced other companies’ attempts to do business in Russia. One such situation involved a joint venture between BP and the Russian company TNK, which eventually devolved into the same tensions that pervaded the Yukos steal. The Russians bristled at Western efforts to control the operations, which led to reports of break-ins at BP executive Bob Dudley’s Moscow apartment, threats of him being detained, and even word that there was poison found in his blood. Dudley, who later became chairman of BP before retiring in 2020, wound up fleeing Russia and the venture was sold to Rosneft.

Resources
Loren Steffy on LinkedIn
Stoney Creek Publishing
 

Categories
Compliance Kitchen

Swiss Sanctions on Russia


Switzerland Imposes Sanctions on Russia.

Categories
Sunday Book Review

March 6, 2022 the Russia/Ukraine edition


In today’s edition of Sunday Book Review:

  • Bloodlands by Timothy Snyder
  • Red Famine by Anne Applebaum
  • Ukraine’s Nuclear Disarmament by Yuri Kostenkov
  • The Frontlines: Essays on Ukraine’s Past and Present by Serhii Plokhy
Categories
EMBARGOED!

EMBARGOED! Episode 45: Russia Invades Ukraine and Triggers the Biggest Week in Economic Sanctions History

After a tumultuous and historic week, Brian and Tim gather themselves to discuss the U.S. (and global) response to Russia’s invasion of Ukraine. They start by diving in to the broad, coordinated economic sanctions aimed at debilitating Russia’s financial sector and Putin’s inner circle, debate how well the new measures will work, and contemplate what could be coming next. They next turn to the significant expansion of export controls implicating Russia and discuss the likely impact. Finally, in the Lightning Round, Brian and Tim bid farewell to DOJ’s China Initiative and read between the lines to decipher DOJ’s ongoing priorities.

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Questions? Contact us at podcasts@milchev.com.
EMBARGOED! is not intended and cannot be relied on as legal advice; the content only reflects the thoughts and opinions of its hosts.
***Stay sanctions free.***

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