US: OFAC Publishes “A Framework for Compliance Commitments”

On 2 May 2019, the US Office of Foreign Assets Control (OFAC) published A Framework for OFAC Compliance Commitments (Framework). This long-awaited document sets...

US: DOJ Guidelines Incentivize Companies to Self-disclose and Cooperate in False Claims Act Cases

On 7 May 2019, the US Department of Justice issued Guidelines for Taking Disclosure, Cooperation, and Remediation into Account in False Claims Act Matters,...

US Department of Justice Issues Update to its Guidance on Evaluating Corporate Compliance Programs

On April 30, 2019, the Assistant Attorney General for the Department of Justice's Criminal Division, Brian Benczkowski, announced the publication of an updated version...

US: Regulations Address FATCA Verification and Certification Requirements

On 21 March 2019, the US Internal Revenue Service (IRS) issued final regulations (the Final Regulations) relating to FATCA verification and certification requirements. FATCA...

Global Legal Guide for Luxury & Fashion Companies

Despite geopolitical shifts, uncertainty and various factors that seem to affect numerous sectors, the global luxury and fashion industry has tripled in the last...

US: What To Expect When You’re Expecting A Compliance Monitor

The settlement agreement has been signed, hands have been shaken, and what seemed to be an endless string of meetings and update calls with...

US Commodity Futures Trading Commission’s Entry Into the Land of Foreign Bribery

On 6 March 2019 the Commodity Futures Trading Commission (CFTC) Division of Enforcement released an Enforcement Advisory addressing companies and individuals not registered with,...

US Department of Justice revises FCPA Corporate Enforcement Policy to encourage adoption of guidance...

Amendments to FCPA Corporate Enforcement Policy In March 12, 2019, the US Department of Justice (DOJ) modified the FCPA Corporate Enforcement Policy (the “Policy”). This...

Connected Compliance: The Global Case for Integration

Leverage the value of connected compliance to your competitive advantage In the autumn of 2017, we spoke with more than 500 UK multinationals about their...

OFAC and State Department Russia Sanctions Developments, Including OFAC Notification to Congress of Intent...

On December 19, 2018, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) submitted a letter to congressional leaders (“Congressional Letter”)...

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