Sanctions Compliance, Policy and Enforcement during the COVID-19 Crisis

Due to the pandemic, the world has seen an unprecedented shift in how people work, play, and get on with day-to-day life. For compliance suites, this means the regulatory waters have become even murkier.

Will the regulator relax restrictions following the pandemic, or are we likely to see renewed and more vigorous requirements? Now, more than ever, compliance suites must keep their finger on the pulse with regard to sanctions issues in order to ensure that their institutions remain fully compliant with global regulations.

In this ACSS webinar, our expert speakers will discuss the vital questions that may be plaguing your mind and your organization during the COVID-19 pandemic.

Duration: 45 minutes

Speakers: Eric J. Rudolph, Max Lerner

Moderator: Anna Sayre, Director of Content

Date: Thursday, April 30, 2020

Time: 12:00 PM – 12:45 PM EST

05:00 PM – 05:45 PM London

06:00 PM – 06:45 PM Amsterdam

You will learn:

  • Regulatory Roundup: How has the pandemic impacted OFAC’s approach to sanctions compliance? Will OFAC relax its sanctions programs on heavily affected countries or increase the onus to comply?
  • Risky Business: Do sanctions compliance officers feel more pressure from the business lines to go into risky countries (now sales are down)?
  • Humanitarian Aid: On March 31, 2020, the first INSTEX transaction was completed by sending medical devices to Iran – Will this be used more often now? If so, for what?
  • Compliance Team Tips: What operational impact has the pandemic had on team availability/ability, budget, and how should compliance suites plan for the future?

Event Registration

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Eric J. Rudolph

Senior Director

FTI Consulting

An attorney by experience and training, Eric has led, managed and participated in compliance reviews domestically and internationally (North America, Europe, Middle East, Africa and Asia), internal investigations, International Traffic in Arms Regulations (ITAR) and Export Administration Regulations (EAR) counseling, jurisdiction and classification analyses, and training efforts. In his practice, Eric focuses on providing practical recommendations concerning risk-based assessment of compliance needs, compliance program design, investigations, audits and reviews, and support of remediation activities. Additionally, Eric has significant experience in working with companies operating under government-appointed compliance monitors/officials, including serving as part of the monitor team in an export controls and sanctions case involving criminal and civil settlements with the Department of Justice (DOJ), Bureau of Industry and Security (BIS) and the Office of Foreign Assets Control (OFAC).

Eric’s experience with sanctions matters includes advising clients on compliance with various sanctions programs administered by OFAC; review of compliance programs; review and recommendations on screening and due diligence procedures to promote compliance with OFAC sanctions programs; investigation of potential violations; advising on sanctions matters in the context of M&A due diligence and integration; and assisting with voluntary self-disclosures.

Previously, Eric worked in the export controls and sanctions practice of a Big 4 accounting firm and ran his own firm before joining the Big 4. Eric also worked for 15 years as an in-house lawyer, including acting as a General Counsel, with manufacturing companies in various industries and has substantial experience in advising Boards and all levels of global executive leadership and management on all aspects of compliance. In addition to export controls and sanctions compliance, Eric also has experience with anti-bribery matters (Foreign Corrupt Practices Act), including policies and procedures, investigations, voluntary disclosures and remediation; and in U.S. Customs Service matters. Eric previously served as a committee liaison to a member of the United States Trade Representative’s Advisory Committee for Trade Policy and Negotiations (ACTPN), the U.S. government’s senior trade advisory panel and, in that capacity, participated in the drafting of ACTPN reports to the President, the Congress, and the Office of the U.S. Trade Representative on several free trade agreements.

Prior to entering in-house legal practice, Eric investigated and litigated fraud cases as a government securities regulator, working with various state and federal law enforcement and regulatory agencies, including on high-profile cases involving Ponzi schemes that resulted in criminal convictions and abusive broker-dealer sales practices.

Max Lerner

Global Head of Sanctions

State Street

Max Lerner is the Global Head of Sanctions for State Street, a leading global bank focused in custodial, asset management and advisory, and administrative services based in Boston. In his role, Max is responsible for: the design, management, and execution of State Street’s global sanctions program; providing global leadership on all sanctions issues and projects, including sanctions screening programs, regulatory remediation and engagement, and policy and business unit advisory; and personnel management and operational oversight of teams based across the globe. Max also sits on State Street’s AML & Sanctions Leadership team, wherein he advises on AML, PEP, cryptocurrency / digital assets, and marijuana issues.

Prior to his tenure at State Street, Max served as Legal Regulatory Counsel at Standard Chartered Bank, a major global bank focused on retail, trade finance, commercial, and correspondent banking, based at its New York office. In that role, Max’s practice focused on three areas: (1) AML & sanctions advisory, (2) dispute resolution management, and (3) regulatory engagement, investigations, and remediation. As the key AML & sanctions counsel based at the New York office, Max worked closely with business units and corporate functions to advise on business transactions and deals, compliance policies and programs, and audit findings. Max was the primary point of contact for government and third-party subpoenas and inquiries, engaged closely with government agencies on investigations, and acted as in-house counsel for US litigation matters. Further, Max was a foundational advisor and in-house counsel in the redesign of Standard Chartered’s AML & sanctions program and remediation plan stemming from its multiple regulatory orders.