Lessons learned: Key Takeaways and Insights on Companies Subject to Penalties
- What do recent US Sanctions enforcement settlements reveal about evolving priorities?
- What are the new features in OFAC settlement agreements and what to expect going forward?
- Highlights for compliance deficiencies or breakdowns that are commonly responsible for sanctions violations
- Enforcement trends on use of US dollar payments; utilising
- non-standard payment; improper due diligence; lack of sanctions compliance; screening software limitations; M&A’s; individual liability and misinterpretation of OFAC regulations.