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Rethinking the Applicability of Secondary Sanctions: Prohibited v. Sanctionable Activity

November 20, 2020 By: Amir Fadavi Ardekani, BNP Paribas* In recent times, the U.S. Government has not been shy about imposing sanctions on activities with no nexus to the U.S. in order to increase its global crack down. The imposition of these so-called ‘secondary...

The U.K.’s Global Human Rights Sanctions Regulations 2020 and the U.K.’s first steps as an autonomous International Sanctioning Body

October 8, 2020 By: Daniel Martin, Partner, HFW* Earlier this summer, having left the E.U. in January, the U.K. took its first steps as a fully autonomous sanctions body. The U.K. has always been a leading state in the implementation and enforcement of sanctions, in...

UK Enforcement Update: OFSI Shows its Teeth as Penalties for Sanctions Violations Jump into the Millions

July 18, 2020 By: Daniel Martin, Partner, HFW* After a slow start, the U.K. sanctions authority - The Office of Financial Sanctions Implementation (OFSI) - has now begun to show its teeth. However, having seen the size of the penalties imposed by OFAC in the last ten...

Combatting Corruption Through Compliance: Part 3: Internal Controls, Training, and Audit

July 06, 2020 By: Scott Nance, Principal, Langley Compliance Consulting LLC* Detecting and preventing corruption should be an integral part of any organization’s efforts in the battle against financial and economic crime. Though we often think of corruption involving...

Combatting Corruption Through Compliance: Part 2: The Five Steps of a Risk Assessment

June 25, 2020 By: Scott Nance, Principal, Langley Compliance Consulting LLC* Detecting and preventing corruption should be an integral part of any organization’s efforts in the battle against financial and economic crime. Though we often think of corruption involving...

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