Compliance Kitchen

The Compliance Kitchen on Understanding the Beneficial Ownership Information Filing Requirement Starting in 2024

Mon, 03 Apr 2023 05:00:00 -0000

Are you aware of the upcoming beneficial ownership information filing requirement that will start in January 2024? The Financial Crimes Enforcement Network (FinCEN) issued their first set of guidance materials, aiming to help individuals and small businesses understand the incoming filing requirement. According to the guidance, "beneficial ownership information" refers to individuals or individual who directly or indirectly own or control a company.

To enhance corporate transparency and discourage illegal activities like money laundering, companies must report the beneficial ownership information to FinCEN. The guideline applies to domestic and foreign reporting companies, including corporations, LLCs, or any other legal entity that was created by filing documents with a secretary of state or similar body. However, exemptions are available, and there are 23 different types of entities exempted from the requirement.

To ensure a smooth transition, FinCEN has put together an online platform for reporting and published frequently asked questions on their website along with an introductory video on YouTube. If you're a business owner or operate a legal entity registered to do business in the U.S, it's essential to start preparing for the beneficial ownership information filing requirement.

Here are three tips to keep in mind:

- Stay updated with the latest guidance materials available on the FinCEN website.

- Ensure that you have all documents and information needed to report beneficial ownership information accurately.

- Identify whether you qualify for any exemptions and seek professional advice if needed.

The Compliance Kitchen Unveils the EU Sanctions on Russia and Explores the Impact

Tue, 21 Mar 2023 15:18:02 -0000

In The Compliance Kitchen podcast, host Silvia Surman dives into a variety of compliance topics. In this episode, Silvia examines sanctions on Russia imposed by the European Union, including asset freezes, travel bans, blocking access to Russia's central bank reserve holdings, and prohibitions on exports of dual use goods and technology, among other sanctions. Silvia also takes a look at how two thirds of the world population is taking a neutral stance on the situation and the economic impact of the sanctions thus far. She references an article from the European Parliamentary Research Service for viewers to explore further. Join Silvia on The Compliance Kitchen to stay up-to-date on international compliance topics.

Key Highlights

EU Sanctions on Russia [00:07]

Impact of International Sanctions on Russia [05:43]

Impact of G7 Sanctions on Russia's Economy [11:12]

Accessing European parliamentary research services [16:35]

Notable Quotes

"Whatever you hear on compliance kitchen is not legal advice, and it should not be used as such."
"Then we had the attempted poisoning of Sergei Skripal and his daughter, they were living in the UK at the time. That was in 2018. So you continued to respond to all these acts with some degree of sanctions or some sanctions regimes that they implemented."
"Then we had the Alexandre Navalny poisonings that was in 2020, 2021. So with that came the EU global human rights sanctions regime."
"Banning transactions with certain Russian state owned military industrial companies disconnecting leading Russian financial institutions from the Swift system."

Compliance Kitchen on Unwrapping the Cloaked: How Russian Oligarchs Evade Sanctions with the Help of Enablers

Mon, 13 Mar 2023 17:40:07 -0000

The Compliance Kitchen, hosted by Siliva Surman, dives into detailed and complex topics looking at all sides of the compliance industry. The recent advisory from the repo task force that Siliva discusses reveals the clever evasion tactics used by Russian elites, including beneficial ownership of legal entities transferred to their children, as well as enablers performing certain functions on their behalf. Russian and other users are able to access sensitive goods and technologies by using freight forwarding businesses in a third country. The Compliance Kitchen is here to provide insight and analysis into these and other compliance topics in an engaging and educational manner.

Key Highlights

Russian Sanctions Evasion Tactics Used by Elites. 00:06

The Use of Enablers to Avoid Sanctions on Russian Oligarchs. 06:13.

Illegal Access to Sensitive Goods and Technologies Through Freight Forwarding Business. 12:18

Notable Quotes

"This is a multilateral effort that has used information sharing and coordination to isolate and pressure sanction Russian individuals and entities."
"The typologies that they identified in this advisory include the use of family member burs and close associates to ensure continued access and control over assets."
"The asset transfers it's being observed that go to family members and close associates sometimes occur immediately before a person is on sanctions list or shortly thereafter. So that indicates sanctions evasion efforts."
"More specifically, the advisory tells us that sanctioned Russian individuals and entities have used the use of expensive real estate to hold value or to own their illicit proceeds through real estate using complex ownership structures to avoid identification of the ultimate beneficial owner."

Compliance Kitchen on Navigating the 10th Package of EU Sanctions and DOJ’s Disruptive Technology Strike Force

Mon, 06 Mar 2023 06:00:00 -0000

The Compliance Kitchen with host Silvia Surman is the podcast you need to stay up-to-date on regulation details. In the most recent episode, Silvia dives into the EU's tenth package of sanctions against Russia and the DOJ's new disruptive technology strike force. Surman covers details such as entities and people added to the Russia sanctions list, additional trade restrictions, enforcement and anti-convention measures, and the prohibition on transmitting dual use items and goods and technology from the EU through Russian territory. Additionally, Surman talks about the DOJ's new strike force encompassing more than 10 cities to enforce U.S. laws protecting advanced technologies from illegal acquisition. Tune into The Compliance Kitchen for the need-to-know information on regulation details!

Highlights Include

EU Sanctions
DOJ Disruptive Technology Strike Force

Notable Quotes

"The EU has added a number of entities and people to the Russia sanctions list."
"Also those who continue to press the Kremlin's propaganda and spread this information in the media."
"The goal is to prevent critical technologies from being acquired or used by certain nation state adversaries such as China, Russia, North Korea, and Iran."
"This is a joint venture that encompasses more than 10 cities and aims to enforce U. S. Laws to protect advanced technologies from illegal acquisition and used by certain nation state adversaries.""

Resources

Silvia Surman on LinkedIn

Compliance Kitchen-Navigating OFAC's Latest Guidance on Russia's Metals and Mining Sector

Fri, 24 Feb 2023 23:21:00 -0000

The Compliance Kitchen, hosted by Silvia Surman, is a podcast that examines and evaluates the changing legal framework of international compliance. On 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 those activities are only authorized by General Licensed 6C. Silvia further elaborates that the license authorizes transactions related to the production, manufacturing, sale, transport, or provision of medicine, medical devices. Tune into Compliance Kitchen to stay up to date with the evolving legal framework of international compliance.

Notable Quotes

1. "This February 24 determination authorizes sanctions on any person that is determined by the government 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 the 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 it was a US person that was 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 such transactions would be normally authorized by General License 8F as in Frank. That 1 authorizes certain energy related transactions or if those activities would be only authorized by General Licensed 6C, and that license authorizes certain transactions related to the production, manufacturing, sale transport or provision of medicine, medical devices, including certain industrial isotopes that are used in nuclear medicine.""

Compliance Kitchen - the Changes in the DOJ Corporate Enforcement Policy

Fri, 10 Feb 2023 22:25:48 -0000

The Compliance Kitchen returns with a wrap-up of the week's top trade and economic sanction issues. In today's episode, Silvia Surman visits the DOJ revised its Corporate Enforcement Policy and the Kitchen looks at the highlights.

Compliance Kitchen on Prolonged EU Sanctions on Russia and More

Mon, 30 Jan 2023 13:58:42 -0000

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 the EU prolongs economic sanctions over Russia’s military aggression against Ukraine; FinCEN designates virtual currency exchange Bitzlato a “Primary Money Laundering Concern” for Russian illicit finance; DOJ obtains guilty plea from a military contractor for rigging bids on government military contracts.

Compliance Kitchen on OFAC and DOJ Developments

Mon, 23 Jan 2023 00:00:00 -0000

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.

Compliance Kitchen Wrap Up for January 16, 2023

Fri, 13 Jan 2023 22:13:05 -0000

The Compliance Kitchen is for those who want to “see what’s cooking” in the never-boring worlds of corporate compliance, white collar crime and global trade. We hope that you will feel comfortable in the Kitchen and listen in and finding it enjoyable. Stories cooking in the kitchen this week include: EU promises upcoming sanctions against Belarus and Iran for assisting Russia in its war against Ukraine; the Czech Republic rolls out its own National Sanctions List; the USITC introduces a new investigations research database system.

The Compliance Kitchen Returns for 2023

Mon, 09 Jan 2023 06:00:00 -0000

OFAC issues preliminary guidance on upcoming price cap covering Russian origin petroleum products, to tag along on the existing guidance and price cap on Russian crude oil. UK’s Export Control Joint Unit publishes a compliance code of practice for export licensing to help exporters with their obligations.

Blocking Russian Banks

Fri, 15 Apr 2022 05:00:00 -0000

The Kitchen looks at Department of Treasury sanctions which are now fully blocking Russia’s largest banks and banning new investment.

OFAC Tech Company Sanctions

Thu, 14 Apr 2022 05:00:00 -0000

The Kitchen looks at new levied OFAC sanctions against Russian tech companies.

EU’s 5th package of Sanctions

Wed, 13 Apr 2022 05:00:00 -0000

The Kitchen considers the EU’s 5th package of sanctions against Russia.

S&P Global Settlement

Tue, 12 Apr 2022 05:00:00 -0000

S&P Global Inc. settlement – apparent violations of Ukraine sanctions in 2016 and 2017.

Australia Tariffs for Belarus and Russia

Mon, 11 Apr 2022 11:38:32 -0000

Australia increases tariffs for products from Belarus and Russia; introduces luxury goods export sanctions for Russia.

Economic Espionage

Fri, 08 Apr 2022 05:00:00 -0000

DOJ convicts GE engineer - economic espionage.

Iran Sanctions Update

Thu, 07 Apr 2022 05:00:00 -0000

US – Iran: Sanctions due to Ballistic Missile Related Activities

SAR Filing Trends

Wed, 06 Apr 2022 05:00:00 -0000

2021 SAR Filing Trend Data Now Available on FinCEN’s Website.

Additional Russia Sanctions

Tue, 05 Apr 2022 05:00:00 -0000

OFAC, State Dept. issue further Russia restrictions and General Licenses.

SEC Proposed Rules on Climate Change Risk

Mon, 04 Apr 2022 11:42:56 -0000

SEC issues proposed rules on climate impact disclosures; requests public comment.

BlockFi Settlement

Fri, 01 Apr 2022 05:00:00 -0000

BlockFi to Pay $100M and pursue registration of its crypto lending product.

UPS Settlement

Thu, 31 Mar 2022 05:00:00 -0000

The Kitchen reviews the recent UPS’ $5.3M settlement for falsely reporting delivery times of U.S. Mail.

OFSI Updates Sanctions Guidance

Wed, 30 Mar 2022 05:00:00 -0000

The Kitchen reviews the UK’s OFSI updated financial sanctions guidance: aggregation under the 50% ownership rule.

EU Freeze and Seize Task Force

Tue, 29 Mar 2022 05:00:00 -0000

New “Freeze and Seize’ Task Force set up by the European Commission against listed Russian and Belarussian oligarchs.

Oligarch Task Force

Mon, 28 Mar 2022 15:47:35 -0000

The Department of Treasury and DOJ launch multilateral Russian Elites, Proxies, and Oligarchs (REPO) task force.

New Russia Tariffs

Fri, 25 Mar 2022 05:00:00 -0000

UK denies Russia Most Favored Nation status; announces new import tariffs on hundreds of Russian products.

Russia Loses MFN Status

Thu, 24 Mar 2022 05:00:00 -0000

Russia loses its “Most Favored Nation” status with EU.

EU’s 4th Package of Sanctions on Russia

Wed, 23 Mar 2022 05:00:00 -0000

The Kitchen reviews the EU’s 4th package of sanctions on Russia.

EU Sanctions Whistleblower Tool

Tue, 22 Mar 2022 05:00:00 -0000

EU rolls out an EU Sanctions Whistleblower Tool for anonymous reporting of sanctions violations.

White House Fact Sheet

Mon, 21 Mar 2022 05:00:00 -0000

White House fact sheet on March 8 Executive Order banning Russian energy imports; OFAC sanctions Duma members; CBP issued implementing guidance on Russian imports.

Task Force KleptoCapture

Fri, 18 Mar 2022 05:00:00 -0000

DOJ announces the launch of Task Force KleptoCapture.

EU Residency Protection for Refugees

Thu, 17 Mar 2022 05:00:00 -0000

EU introduces residency protection measures to displaced population of Ukraine.

SWIFT Bans

Wed, 16 Mar 2022 05:00:00 -0000

EU excludes Russian and Belarusian banks from SWIFT; restricts maritime and telecom exports to Russia.

Russia Shipping Bans

Tue, 15 Mar 2022 05:00:00 -0000

The UK bans Russian ships from UK ports; additional economic measures and asset freezes on Russian businessmen.

EU Sanctions on Russia Update

Mon, 14 Mar 2022 15:41:03 -0000

EU sanctions state-owned outlets RT/Russia Today and Sputnik broadcast; BIS bans export of luxury goods to Russia, Belarus.

Additional EU Banking Sanctions

Fri, 11 Mar 2022 06:00:00 -0000

EU bans some Russian banks from SWIFT; issues more restrictions.

Swiss Sanctions on Russia

Thu, 10 Mar 2022 06:00:00 -0000

Switzerland Imposes Sanctions on Russia.

Additional Belarus Sanctions

Wed, 09 Mar 2022 06:00:00 -0000

Treasury rolls out additional sanctions on Belarus for facilitating Russian aggression in Ukraine.

Singapore Readies Sanctions

Tue, 08 Mar 2022 06:00:00 -0000

Singapore readies a sanctions package against Russia.

Russia Removal from SWIFT

Mon, 07 Mar 2022 06:00:00 -0000

The Kitchen considers the Russia and removal from SWIFT – a joint statement of the allies.

UK’s Second Wave of Sanctions on Russia

Fri, 04 Mar 2022 06:00:00 -0000

This week the Compliance Kitchen is looking at sanctions levied on Russia because of its invasion of Ukraine. Today, UK’s second wave of sanctions on Russia.

US Sanctions on Russia, Putin and Nord Stream 2

Thu, 03 Mar 2022 06:00:00 -0000

This week the Compliance Kitchen is looking at sanctions levied on Russia because of its invasion of Ukraine. Today, the US Sanctions on Russia, Putin and Nord Stream 2.

EU Sanctions on Russia

Wed, 02 Mar 2022 06:00:00 -0000

This week the Compliance Kitchen is looking at sanctions levied on Russia because of its invasion of Ukraine. Today, the EU sanctions package on Russia in regards to Ukraine.

UK Sanctions on Russia

Tue, 01 Mar 2022 06:00:00 -0000

This week the Compliance Kitchen is looking at sanctions levied on Russia because of its invasion of Ukraine. Today, the UK’s first wave of sanctions on Russia in regards to Ukraine.

Sanctions on so-called Donetsk and Luhansk People’s Republics

Mon, 28 Feb 2022 12:14:32 -0000

This week the Compliance Kitchen is looking at sanctions levied from the Russia invasion of Ukraine. Today, the US introduces Comprehensive Sanctions on so-called Donetsk and Luhansk People’s Republics.

DDTC Updated Guidance to Agreements Under ITAR

Fri, 25 Feb 2022 06:00:00 -0000

The Kitchen considers the Directorate of Defense Trade Controls (DDTC) updated guidance to Agreements under ITAR.

Proposed Changes to ITAR’s Nationality Rule

Thu, 24 Feb 2022 06:00:00 -0000

State Department’s proposed changes to ITAR’s nationality rule; request for public comment.

Treasury Study Re: AML and the Art Trade

Wed, 23 Feb 2022 06:00:00 -0000

Treasury study: Facilitation of Money-Laundering; Terror Finance Through the Trade in Art.

Import Duties Evasion

Tue, 22 Feb 2022 06:00:00 -0000

The Kitchen looks at CBP import duties evasion regarding Vivaldi Commercial LLC, Vivaldi Interiors LLC.

Uyghur Forced Labor Prevention Act

Mon, 21 Feb 2022 06:00:00 -0000

CBP details out the Uyghur Forced Labor Prevention Act; requests public comment.

OFAC Sanctions Pretend NGO

Fri, 18 Feb 2022 06:00:00 -0000

OFAC sanctions World Human Care, a pretend humanitarian NGO for financing violent extremists.

BIS Update to Unverified List

Thu, 17 Feb 2022 06:00:00 -0000

Commerce Department’s BIS issues revisions to the Unverified List; adds 33 Chinese entities.

OFAC issues Ethiopia Sanctions Regs

Wed, 16 Feb 2022 06:00:00 -0000

OFAC issues Ethiopia Sanctions Regulations in relation to the human rights crisis in the country.

Sanction Termination Re: Burundi

Tue, 15 Feb 2022 06:00:00 -0000

OFAC terminates sanctions against Burundi.

Bitcoin Hack Arrests

Mon, 14 Feb 2022 11:51:00 -0000

The DOJ arrests two for Bitcoin hack and money laundering scheme.

OFAC issues updated FAQs on the Afghanistan sanctions

Fri, 11 Feb 2022 06:00:00 -0000

OFAC issues updated FAQs on the Afghanistan sanctions regime to facilitate humanitarian aid.

EU Prohibits Political Disinformation

Thu, 10 Feb 2022 06:00:00 -0000

EU to establish sanctions regime against foreign State actors for spreading political disinformation.

State Department Settlement Re:; Torrey Pines Logic, Inc. & Dr. Leonid Volfson

Wed, 09 Feb 2022 06:00:00 -0000

State Department settlement for alleged export violations: Torrey Pines Logic, Inc. & Dr. Leonid Volfson.

OFAC amends Transnational Criminal Organizations Sanctions Regulations

Tue, 08 Feb 2022 06:00:00 -0000

The Kitchen reviews OFAC amendment of Transnational Criminal Organizations Sanctions Regulations.

State Department Report on Russia

Mon, 07 Feb 2022 06:00:00 -0000

The Kitchen reviews the recent State Department report on RT and Sputnik’s Role in Russia’s Disinformation and Propaganda Ecosystem.

OFAC Update Re: Ukraine

Fri, 04 Feb 2022 06:00:00 -0000

OFAC issues Ukraine-related General Licenses 13Q and 15K and amended FAQs.

Sanctions Against North Koreans Supporting WMDs

Thu, 03 Feb 2022 06:00:00 -0000

In this episode, the Kitchen looks at the recent Department of the Treasury and Department of State efforts to target North Koreans supporting WMDs.

Myanmar Business Advisory

Wed, 02 Feb 2022 06:00:00 -0000

In this episode, the Kitchen provides a Myanmar business advisory.

FinCEN Solicits Comments

Tue, 01 Feb 2022 06:00:00 -0000

FinCen solicits public comment on temporary sharing of Suspicious Activity Reports.

DOJ & FTC Public Comment on Illegal Mergers

Mon, 31 Jan 2022 12:22:05 -0000

Department of Justice and Federal Trade Commission open public comment window - enforcement against illegal mergers.

Update on China Issues

Fri, 28 Jan 2022 06:00:00 -0000

Export restrictions; sanctions on 3 PRC companies - missile proliferation activities.

UK Plastic Packaging Tax

Thu, 27 Jan 2022 06:00:00 -0000

UK’s new Plastic Packaging Tax set to begin soon.

EU Russia Sanctions Over Ukraine

Wed, 26 Jan 2022 06:00:00 -0000

EU prolongs Russia sanctions over the Ukraine situation.

OFAC FAQs on Libor

Tue, 25 Jan 2022 06:00:00 -0000

OFAC answers FAQs on sanctions and the discontinuation of LIBOR.

Guilty Plea for Economic Espionage

Mon, 24 Jan 2022 18:58:02 -0000

The DOJ obtains a guilty plea on conspiracy to commit economic espionage.

OFAC Settlement with Sojitz (Hong Kong) Limited

Fri, 21 Jan 2022 06:00:00 -0000

Following Iran sanctions violations by its employees, Sojitz (Hong Kong) Limited settles with OFAC.

OFAC-TD Bank Settlement

Thu, 20 Jan 2022 06:00:00 -0000

OFAC announces TD Bank settlement – sanctions violations due to customer screening gaps.

OFAC Sanctions AirBnB

Wed, 19 Jan 2022 06:00:00 -0000

OFAC – Airbnb Payments, Inc. settlement: Cuba sanctions violations.

Treasury List PRC Related Companies

Tue, 18 Jan 2022 06:00:00 -0000

Treasury lists 8 companies as part of the PRC's Military-Industrial Complex.

FinCEN Penalizes Community Bank

Mon, 17 Jan 2022 06:00:00 -0000

FinCEN announced CommunityBank of Texas, N.A. penalty for Bank Secrecy Act violations.

ITAR Sanctions Re: Cambodia

Fri, 14 Jan 2022 06:00:00 -0000

The State Department amends ITAR to restrict trade of defense articles and services with Cambodia.

EU Sanctions on Mali

Thu, 13 Jan 2022 06:00:00 -0000

EU amends its sanctions regime to issue autonomous restrictions on Mali.

UK Changing Sanctions List

Wed, 12 Jan 2022 06:00:00 -0000

UK announces upcoming structure and format changes to its sanctions list.

Strategy for Countering Corruption

Tue, 11 Jan 2022 06:00:00 -0000

The Biden Administration issues its 5 pillar Strategy on Countering Corruption.

FinCEN opens public comment window

Mon, 10 Jan 2022 06:00:00 -0000

FinCEN opens public comment window: how to modernize the U.S. AML/CFT regulatory regime.

Year End Wrap Up

Tue, 21 Dec 2021 06:00:00 -0000

The Kitchen wraps up its 2021 with a look back at some of its top stories from the past year.

Cambodia Update - ITAR

Fri, 17 Dec 2021 06:00:00 -0000

ITAR: addition of Cambodia to the List of Proscribed Countries.

Cambodia Update - Department of Commerce

Thu, 16 Dec 2021 06:00:00 -0000

The Department of Commerce adds export controls on Cambodia: corruption; regional security concerns.

BIS Update

Wed, 15 Dec 2021 06:00:00 -0000

BIS lists foreign entities: support of foreign military applications, proliferation

Forex Trading Violations

Tue, 14 Dec 2021 06:00:00 -0000

EU fines 5 banks for cartel activity in Forex spot trading.

EU Council on transparency of crypto-asset transfers

Mon, 13 Dec 2021 12:51:36 -0000

Update from Europe - EU Council on transparency of crypto-asset transfers.

EU Digital Finance Package

Fri, 10 Dec 2021 06:00:00 -0000

EU digital finance package: crypto assets market, blockchain regulation.

More Belarus Sanctions

Thu, 09 Dec 2021 06:00:00 -0000

EU's 5th package of Belarus sanctions: instrumentalization of migrants.

DOJ settlement: Immigration and Employment Discrimination

Wed, 08 Dec 2021 06:00:00 -0000

DOJ - Gap, Inc. settlement: immigration and employment discrimination.

EU Regulation of Big Tech

Tue, 07 Dec 2021 06:00:00 -0000

Regulating "big tech" - EU to level competition playing field in the digital space.

Digital Services Act

Mon, 06 Dec 2021 06:00:00 -0000

Update from Europe - Council of the EU aligns on Digital Services Act.

The Kimberly Process

Fri, 03 Dec 2021 06:00:00 -0000

The diamond trade’s Kimberley Process and the 2021 Plenary. Stop by to hear more.

More Nord Stream 2 Pipeline Project Sanctions

Wed, 01 Dec 2021 06:00:00 -0000

The State Department announced additional sanctions on the Nord Stream 2 pipeline project.

New Nicaragua Sanctions

Wed, 01 Dec 2021 06:00:00 -0000

US adds sanctions on Nicaragua following recent sham elections.

Sanctions on Burundi Terminated

Tue, 30 Nov 2021 06:00:00 -0000

Seeing improvements, the President terminates US sanctions program on Burundi. Tune in to find out what does it mean and how do pending or future investigations fit into

FinCEN Notice on Environmental Crimes

Mon, 29 Nov 2021 06:00:00 -0000

FinCEN publishes a Notice on environmental crimes and related illicit financial activity. Drop by for a quick review.

Mashreqbank Settlement

Wed, 24 Nov 2021 06:00:00 -0000

Mashreqbank agrees on a $100M settlement with the US government over Sudan sanctions violations.

Export Control and the Movement of Contraband

Tue, 23 Nov 2021 06:00:00 -0000

The pandemic has not slowed down the movement of contraband. The CBP sees record seizures of counterfeit luxury and pharma goods.

Cambodia Business Advisory

Mon, 22 Nov 2021 06:00:00 -0000

OFAC issues Cambodia Business Advisory on High-Risk Investments and Interactions. Stop by for more detail.

Treasury and State Department Update

Fri, 19 Nov 2021 06:00:00 -0000

Treasury designates ransomware operators; State Department offers reward to locate REvil players.

BIS Penalty Re: Huawei

Thu, 18 Nov 2021 06:00:00 -0000

BIS issues a penalty and audit requirements to a US exporter for unlicensed shipments to Huawei.

DOJ Convict for Export of Rebreathers

Wed, 17 Nov 2021 06:00:00 -0000

The DOJ obtains a conviction for export of rebreathers without a BIS license. The Kitchen reviews the press release and brings you the summary.

FinCEN Update

Tue, 16 Nov 2021 06:00:00 -0000

FinCEN issued an updated “Advisory on Ransomware and the Use of the Financial System to Facilitate Ransom Payments”. Tune in for more details as the Kitchen reviews this latest resource.

Department of Commerce Adds More Groups

Mon, 15 Nov 2021 06:00:00 -0000

Commerce adds NSO Group, others, to Entity List for malicious cyber activities. Stop by the Kitchen to hear more.

DOJ Anti-trust Action Against Publishers

Fri, 12 Nov 2021 06:00:00 -0000

The Kitchen takes a look at a recent anti-trust action, as the DOJ aims to stop a proposed acquisition among major book publishers.

Stablecoin

Thu, 11 Nov 2021 06:00:00 -0000

The US government issues a report and recommendation on Stablecoin. Tune in for more on this

The SEC, Twitter and Penny Stock Manipulation

Wed, 10 Nov 2021 06:00:00 -0000

The SEC obtained an injunction and asset freeze to halt penny stock price manipulation on Twitter.

OFSI Sanction Guidance Update

Tue, 09 Nov 2021 06:00:00 -0000

The UK’s OFSI updates its sanctions guidance for non-profits and NGOs in light of the Taliban takeover. Stop by the Kitchen to get the scoop.

Colonial Pipeline Hack Update

Mon, 08 Nov 2021 19:50:06 -0000

The State Department offers a large reward to bring those behind the Colonial Pipeline ransomware incident to account. The Kitchen stopped by for more detail – tune in for a quick update.

Unmanned Drones and Sanction Designations

Fri, 05 Nov 2021 05:00:00 -0000

The US designates 6 involved in Iran’s destabilizing unmanned aerial vehicle activities. Stop by to get the scoop.

FAFT and FinCEN Updates

Thu, 04 Nov 2021 05:00:00 -0000

FATF identifies jurisdictions with AML, counter-proliferation deficiencies. The Kitchen takes a closer look at what’s cooking in the FinCEN kitchen.

Climate Change as Financial Stability Risk

Wed, 03 Nov 2021 05:00:00 -0000

FSOC report on climate change as a risk to US financial stability. Tune in for more details.

Commerce Tightens Exports

Tue, 02 Nov 2021 05:00:00 -0000

Commerce tightens exports of items that can be used for surveillance of private citizens. The Kitchen reviews the interim final rule - stop by for more.

Facebook DOL Settlement

Mon, 01 Nov 2021 05:00:00 -0000

Facebook settles with the DOJ and the DOL over discriminatory hiring practices toward US applicants. Tune in to hear more as the Kitchen reviews this update.

Credit Suisse and Tuna Boats

Fri, 29 Oct 2021 05:00:00 -0000

Credit Suisse resolves a Mozambique loan case for $547M. Listen in for more on this international investigation and enforcement effort.

Bribery in Defense Industry

Thu, 28 Oct 2021 05:00:00 -0000

A CEO of a major US government defense contractor is charged with bribery. The Kitchen reviews the DOJ release - drop in for more.

Bid Rigging on DoD Contracts

Wed, 27 Oct 2021 05:00:00 -0000

The DOJ obtains guilty pleas from two former security services executives for bid rigging of DoD security contracts. Stop by to get the scoop.

Supermax Corporation Withhold Release Order

Tue, 26 Oct 2021 05:00:00 -0000

As more forced labor practices surface, the CBP issues another Withhold Release Order. This time it is Supermax Corporation Bhd. The Kitchen takes a look at this announcement and the underlying law that the CBP relies on.

Boeing Chief Technical Pilot Indicted

Mon, 25 Oct 2021 05:00:00 -0000

A Texas grand jury indicts former Boeing 737 MAX Chief Technical Pilot. Listen in for more detail on this development.

OFAC Guidance Re: Virtual Currency

Fri, 22 Oct 2021 05:00:00 -0000

The Kitchen takes a look at the newly published OFAC guidance for the virtual currency industry. Stop by to get the scoop.

BIS administrative settlement with VTA Telecom Corporation

Thu, 21 Oct 2021 05:00:00 -0000

In this episode, we look at what went into the making of a BIS administrative settlement with VTA Telecom Corporation, due to EAR violations.

Braskem Ex-CEO Sentenced

Wed, 20 Oct 2021 05:00:00 -0000

The DOJ issued a press release of a sentencing of a Brazilian national who is the ex-CEO of Braskem S.A. The Kitchen stopped by for more detail on this. Meanwhile, the Treasury Department issued a list of countries that may require boycott participation. Tune in for more.

UK’s Office of Financial Sanctions counter-terrorism guidance

Tue, 19 Oct 2021 05:00:00 -0000

UK’s Office of Financial Sanctions Implementation published counter-terrorism legislation guidance to NGOs and those in the financial sector. Tune in as the Kitchen highlights the main ingredients.

Atomic Energy Act Enforcement Action

Mon, 18 Oct 2021 05:00:00 -0000

The Kitchen reviews the recent DOJ’s espionage charges against a husband-wife team, accused of violating the Atomic Energy Act.

Penalty for Crypto Services to North Korea

Fri, 15 Oct 2021 05:00:00 -0000

The DOJ obtains a guilty plea to providing crypto services to N Korea, in violation of US sanctions. Stop by as the Kitchen reviews the details.

Penalty for Hacking Services for Hire

Thu, 14 Oct 2021 05:00:00 -0000

The Kitchen looks at what is cooking at the DOJ, as it assesses a $1.68M penalty to ex U.S. intelligence & military personnel for provision of hacking-related services for hire.

Trade Sanctions Evasion Enforcement Action

Wed, 13 Oct 2021 05:00:00 -0000

DOJ sentences an owner of a Russian energy company for U.S. trade sanctions evasion.

Forced Labor Guidance

Tue, 12 Oct 2021 05:00:00 -0000

CBP issues a forced labor program visual guidance. Listen in as the Kitchen reviews this resource for importers.

BIS Penalty for Vorago

Mon, 11 Oct 2021 11:26:04 -0000

The BIS issues a penalty to a Texas company for conspiracy to divert controlled items to Russia. The Kitchen stops by for more detail.

Devon Energy DOJ Enforcement Action

Fri, 08 Oct 2021 05:00:00 -0000

The DOJ settles with Devon Energy Companies for underpayment of royalties from federal lands. Listen in for more detail.

SEC Crowdfunding Regulations

Thu, 07 Oct 2021 05:00:00 -0000

The Kitchen looks at the SEC’s first case that involves crowdfunding regulation.

Nonproliferation Financing Risks Report

Wed, 06 Oct 2021 05:00:00 -0000

The UK issues its first nonproliferation financing risks report. Listen in for more details.

OFAC Sanctions Cameron International Corporation and Schlumberger

Tue, 05 Oct 2021 05:00:00 -0000

OFAC settles with Cameron International Corporation and Schlumberger Rod Lift, Inc over Russia and Sudan sanctions violations. Listen in as the Kitchen reviews in more detail.

Huawei

Mon, 04 Oct 2021 05:00:00 -0000

Huawei’s CFO admits to misleading a global financial institution. The Kitchen takes a closer look at a recently published DPO between the CFO and the DOJ.

Treasury and Humanitarian Issues

Fri, 01 Oct 2021 05:00:00 -0000

In this episode, the Kitchen takes a look at how the Treasury Department facilitates humanitarian assistance in Afghanistan.

SEC Issues

Thu, 30 Sep 2021 05:00:00 -0000

The SEC charges companies with illegal offering of digital assets and stocks; the Kitchen takes a closer look what is cooking in the securities area.

Treasury’s actions against cybercrime and ransomware

Wed, 29 Sep 2021 05:00:00 -0000

In this episode, The Kitchen takes a look at the Treasury’s actions against cybercrime and ransomware.

OFAC Sanctions Re: Colombia

Tue, 28 Sep 2021 05:00:00 -0000

Stop by the Kitchen to hear more as OFAC sanctions significant drug traffickers and their companies in Colombia.

DOJ Enforcement Action Re: Iran Sanctions

Mon, 27 Sep 2021 10:42:47 -0000

The Kitchen takes a look at a recent DOJ enforcement action, where the Department charged 3 with Iran sanctions violations and smuggling of unknown biological substances subject to regulations into the US. Listen in for more detail.

Illegal Exports to China

Fri, 24 Sep 2021 05:00:00 -0000

Today, the Kitchen reviews a DOJ prosecution of a Chinese national responsible for illegal military items exports to the PRC.

SEC and Cybersecurity Deficiencies

Thu, 23 Sep 2021 05:00:00 -0000

In this episode, the Kitchen looks at a recent SEC charge of 8 firms in 3 actions with deficient cybersecurity procedures.

UK Frozen Asset Review

Wed, 22 Sep 2021 05:00:00 -0000

In this episode, The Kitchen reviews the UK’s annual Frozen Assets review and reporting, including how to and where to submit your report to the OFSI timely.

The Forced Labor Imports Enforcement Process

Tue, 21 Sep 2021 05:00:00 -0000

The CBP modifies Forced Labor Finding on a company with facilities in Malaysia. Stop by to hear more about the modification and the forced labor imports enforcement process in general.

AML in Japan

Mon, 20 Sep 2021 05:00:00 -0000

The Kitchen reviews the 2021 report issued by the Financial Action Task Force on AML measures in Japan.

EU and Dual Use Sanctions

Fri, 17 Sep 2021 05:00:00 -0000

The EU issued its new and updated dual use items export regulations and The Kitchen took a look at the main points.

Additional Sanctions on Russia

Thu, 16 Sep 2021 05:00:00 -0000

The State Department published a fact sheet of additional sanctions on Russia in regards to the Navalny poisoning situation. The Kitchen summarizes the latest restrictions.

OFAC Settlement with NewTek

Wed, 15 Sep 2021 05:00:00 -0000

In this episode, The Kitchen reviews OFAC’s settlement with NewTek, Inc. over apparent violations of Iran sanctions.

CPB FAQ's Re: Forced Labor

Tue, 14 Sep 2021 05:00:00 -0000

The CBP recently answered FAQs in regards to its detection and enforcement of regulations against imports of products made with forced labor. Stop by to hear a summary from The Kitchen on imports compliance and exclusion from CBP’s Withhold Release Orders.

UK Trade Sanctions Re: Afghanistan

Mon, 13 Sep 2021 09:54:06 -0000

The UK’s Office of Financial Sanctions Enforcement issued a guidance on the developing situation in Afghanistan. Listen in as The Kitchen takes a closer look.

Insurance Sector Climate Risks

Fri, 10 Sep 2021 05:00:00 -0000

The Treasury Department invites public comments on climate-related financial risks in the insurance sector. The Kitchen reviews the details of this request for information.

Anti-Dumping Orders

Thu, 09 Sep 2021 05:00:00 -0000

Today, the Compliance Kitchen looks at what ingredients go into a request for an administrative review of an anti-dumping or countervailing duty order.

Sudan Sanctions Violations

Wed, 08 Sep 2021 05:00:00 -0000

In this episode, we look at Bank of China (UK) Limited’s (“BOC UK”) agreement to pay over $2.3M to settle its potential civil liability for violations of the (now repealed) Sudan Sanctions Regulations.

OFAC Settlement on Syria & Iran Sanctions

Tue, 07 Sep 2021 05:00:00 -0000

The Kitchen takes a closer look at a recent OFAC settlement with First Bank and JC Flowers & Co. in regards to Iran & Syria Sanctions.

DOJ Enforcement Action Re: World Mining and Oil Supply

Mon, 06 Sep 2021 11:26:19 -0000

In this episode, the Kitchen takes a look at a DOJ action against World Mining and Oil Supply company over allegations of violation of Export Control Reform Act and a related conspiracy.

OFAC license extension on Certain Iranian Goods

Fri, 03 Sep 2021 05:00:00 -0000

In this episode, the Kitchen reviews an OFAC license extension, allowing for certain education materials to be exported to Iran.

EU’s Blocking Statute

Thu, 02 Sep 2021 05:00:00 -0000

In this episode, the Kitchen looks at the EU’s Blocking Statute and the recent amendment initiative by the European Commission.

Executive Order on the NordStream 2 pipeline

Wed, 01 Sep 2021 05:00:00 -0000

The Kitchen reviews a new Executive Order in regards to the NordStream 2 pipeline. Next, we take a look at more sanctions against Nicaragua’s political actors;

Paraguay AML Issues

Tue, 31 Aug 2021 05:00:00 -0000

The Treasury Department sanctions an extensive money laundering network in Paraguay. The Kitchen takes a closer look at the operation.

Dynatex International Enforcement Action

Mon, 30 Aug 2021 05:00:00 -0000

In this episode, the Kitchen takes a look at a settlement between the BIS and a California company, Dynatex International, over allegations of Export Administration Regulations violations.

State Department ISN Update

Fri, 27 Aug 2021 05:00:00 -0000

The State Department’s ISN restricts 8 entities for proliferation activities and bans U.S. government procurement. The Kitchen reviews this action in more detail.

Cuba Fact Sheet

Thu, 26 Aug 2021 05:00:00 -0000

In this episode, the Kitchen looks at a recently issued Fact Sheet coming to us from the BIS and OFAC on supporting Cubans’ access to reliable information and Internet service.

Cuba Sanctions Update

Wed, 25 Aug 2021 05:00:00 -0000

The US presses on with additional sanctions on Cuban officials due to the continued government violence in response to public protests on the island. With the recent developments in Afghanistan reaching a boiling point, the UK excludes it from 5 categories of Open General Export Licenses. The Kitchen reviews which categories are in the export play and what are exporters to do next.

Sanctions Against Oil Smuggling Network

Tue, 24 Aug 2021 05:00:00 -0000

The US sanctions an international oil smuggling network for acting as intermediary to support Iran’s illicit activities. The Kitchen is there to take a closer look.

FinCEN BitMEX Enforcement Action

Mon, 23 Aug 2021 05:00:00 -0000

In this episode, the Kitchen takes a look at FinCEN’s $100M enforcement action against BitMEX for alleged violations of the Bank Secrecy Act.

Keysight Technologies

Fri, 20 Aug 2021 05:00:00 -0000

The Kitchen takes a look at a State Department settlement with Keysight Technologies for alleged export violations.

UK Enforcement of Crimea Sanctions

Thu, 19 Aug 2021 05:00:00 -0000

The Kitchen reviews a recent enforcement action from the UK, penalizing a company for money transfers that were deemed prohibited under EU’s Crimea sanctions regulations.

SEC Whistleblower Award

Wed, 18 Aug 2021 05:00:00 -0000

In this episode, we look at the SEC’s awards to whistleblowers of over $4M and a recent update from the US Customs as they issue a Withhold Release Order on foreign origin products due to forced labor harvesting practices.

DOJ Sanctions on North Korea Trade

Tue, 17 Aug 2021 05:00:00 -0000

The Kitchen reviews a recent seizure by the DOJ of a tanker used for illegal shipments into North Korea.

Updated UK Financial Action Task Force Guidance

Mon, 16 Aug 2021 05:00:00 -0000

The Kitchen takes a look at the UK’s Financial Action Task Force Guidance on Proliferation Financing Risk Assessment and Mitigation.

UK Annual Report on Export Controls

Fri, 13 Aug 2021 05:00:00 -0000

The Kitchen takes a look at the annual report on strategic export controls published by the UK, the export licensing stats as well as enforcement actions and goods seizures levels for the last year.

More on Cuba Sanctions

Thu, 12 Aug 2021 05:00:00 -0000

The State Department and OFAC sanction Cuban police and its leaders as the protests on this island continue to be answered with violence on the part of the government. The Kitchen then heads to Nicaragua, which received sanctions by the EU for continued human rights violations.

EU Guidance on Infrastructure

Wed, 11 Aug 2021 05:00:00 -0000

The EU adopts guidance on infrastructure projects vis-a-vis climate change demands and the Kitchen is there to look into the details of as well as what is “climate proofing” under this technical guidance.

New Syria Sanctions

Tue, 10 Aug 2021 05:00:00 -0000

The Kitchen reviews the Treasury Department’s sanctions on the Syrian prisons system, armed groups, terrorist fundraisers and financial facilitators. The EU adopts a framework for Lebanon sanctions of asset freezes and travel bans against those undermining the rule of law in that country.

New Cuba Sanctions

Mon, 09 Aug 2021 05:00:00 -0000

US imposes more sanctions against Cuban armed forces ministry and its Black Berets in response to the island’s violent suppression of public protests; After the State Department’s business advisory on Hong Kong, China issues reciprocal sanctions. The Kitchen is there to take a closer look at these developments.

OFAC sanctions programs violations

Fri, 06 Aug 2021 05:00:00 -0000

Today, we review a recent OFAC settlement over sanctions programs violations. The Kitchen looks into what the government found to be a mitigating and aggravating factor. Then we touch on the Framework for OFAC Compliance Commitments and align it with this enforcement action.

DOJ Sentencing for Illegal Export to China

Thu, 05 Aug 2021 05:00:00 -0000

Listen in as the Kitchen review a recent DOJ sentencing for conspiring to illegally export semiconductor chips to China.

Canada sanctions on Nicaragua

Wed, 04 Aug 2021 05:00:00 -0000

Today, the Kitchen takes a look at the recent Canada sanctions against key members of the Nicaraguan government. Next we take a look at the UK’s 2020 report on strategic export controls.

Honduran First Family

Tue, 03 Aug 2021 05:00:00 -0000

In this episode, we will look at the recent action by the State Department as it designates the former Honduran first family and issues a travel ban for significant corruption. Next, Commerce Department’s BIS adds to the Entity List 6 Russian IT companies that were previously designated by OFAC.

New Belarus Sanctions from the UK

Mon, 02 Aug 2021 05:00:00 -0000

Listen in as the Kitchen takes a look at the recent Belarus sanctions news from the UK, where the government issues Belarus General License for Air Traffic Control Services and few days later Designates Belarusian JSC AGAT-Electromechanical Plant. Across the big pond, OFAC issues General License 5G for PDVSA 8.5% Bond.

OFAC Enforcement Action Re: Iran

Fri, 30 Jul 2021 05:00:00 -0000

In this episode, we take a look at a recent OFAC settlement over Iran sanctions violations.

Russia and FinCEN Updates

Thu, 29 Jul 2021 05:00:00 -0000

The Kitchen heads to Russia where another foreign NGO is marked as “undesirable.” Back in the States, FinCEN is getting ready for another ransomware themed FinCEN Exchange.

Business Advisory Re: Hong Kong

Wed, 28 Jul 2021 05:00:00 -0000

The State Department issues a business advisory to caution U.S. businesses about emerging risks to their operations and activities in Hong Kong. Listen in as the Kitchen brings you more details on this release.

FDIC and 3rd Party Risk

Tue, 27 Jul 2021 05:00:00 -0000

The FDIC invites comments on proposed guidance to banking institutions on managing 3rd party relationships risks. The Kitchen explores the timeline, applicability and what to comment on.

EU Forced Labor Due Diligence Guidance

Mon, 26 Jul 2021 10:12:17 -0000

In this episode, the Kitchen looks at EU issues Forced Labor Due Diligence Guidance for supply chains and the Kitchen takes a closer look at this latest advisory in the area of modern slavery detection and prevention.

BIS Update

Fri, 23 Jul 2021 05:00:00 -0000

Things are bubbling in the Commerce Department as BIS add 34 companies to the Entity List due to China’s continue human rights abuses and Iranian and Russian procurement without a license. The Kitchen takes a look at the new Xinjiang supply chain business advisory published by the State Department as things continue to heat up in China.

Nicaragua Update

Thu, 22 Jul 2021 05:00:00 -0000

The Kitchen heads South to look at what’s happening with Nicaragua as the US revokes visas of some associated with the Ortega-Murillo regime. EU rolls out a temporary VAT exception – listen in to get more on what products can benefit.

EU, OFAC and Venezuela updates

Wed, 21 Jul 2021 05:00:00 -0000

The Minsk agreements continue to go unimplemented, so the EU extends Russia sanctions again; OFAC grants an export license for certain petroleum products destined for Venezuela and the Kitchen is there to look into the details.

UK Update on Import Tariffs

Tue, 20 Jul 2021 05:00:00 -0000

The UK’s Department for International Trade updated its guidance on import tariffs. Because of the COVID pandemic, some tariffs and VAT have been removed on certain goods. The Kitchen explores where to go and how to look up if your product qualifies for a duty break and how much duty should you expect to pay.

FinCen Priorities

Mon, 19 Jul 2021 05:00:00 -0000

The Financial Crimes Enforcement Network (FINCEN) issued a policy on government-wide priorities (“Priorities”) for anti-money laundering (AML) and countering the financing of terrorism (CFT). The Priorities identify and describe the most significant AML/CFT threats that the US is facing – the Kitchen is there to take a closer look at what goes into this recipe.

BIS Update

Sun, 18 Jul 2021 05:00:00 -0000

FCA Settlement and More Belarus Sanctions

Fri, 16 Jul 2021 05:00:00 -0000

In this episode, the Kitchen explores a recent DOJ settlement with a US government contractor that was brought about through a whistleblower, under the False Claims Act. Next, we take a peek at what is cooking in Switzerland, as the government joins the rest of the world and issues sanctions against Belarus.

OFAC Blocked Property Report

Thu, 15 Jul 2021 05:00:00 -0000

The Kitchen reminds all that the annual OFAC blocked property report deadline is coming up. We look at this process in more detail, including how and where to file and, importantly, what OFAC says should not be reported.

State Department and Corrupt Actors

Wed, 14 Jul 2021 05:00:00 -0000

The Kitchen takes a peek into the newly released Corrupt Actors Report from the State Department, covering numerous politically exposed persons from Honduras, El Salvador and Guatemala.

OSFI and Reasonableness

Tue, 13 Jul 2021 05:00:00 -0000

The Kitchen looks into the UK’s Office of Financial Sanctions Implementation recent guidance around licenses to access frozen funds to cover legal fees and maintenance expenses. OFSI looks at one ingredient in particular: that of “reasonableness” and the Kitchen is there to see what goes into the recipe for a successful license grant.

Data Transfers into the UK

Mon, 12 Jul 2021 05:00:00 -0000

Following the EU’s adoption of Adequacy Decisions that the Kitchen covered in a prior episode, the UK’s Department for International Trade issued an updated guidance on data transfers into the UK. The Kitchen takes a look at the guidance that points to sources on data transfers, IP, copyright and data protection both coming into and leaving the UK.

State Department and Corrupt Actors

Sun, 11 Jul 2021 05:00:00 -0000

The Kitchen takes a peek into the newly released Corrupt Actors Report from the State Department, covering numerous politically exposed persons from Honduras, El Salvador and Guatemala.

From Russia With Love

Sat, 10 Jul 2021 05:00:00 -0000

The Kitchen looks at what has been cooking in the Russia’s Prosecutor General’s office as they add several more foreign NGOs to its “undesirable entity” list.

SEC Office of the Whistleblower

Fri, 09 Jul 2021 05:00:00 -0000

The Kitchen looks at the SEC’s Office of the Whistleblower and the whistleblower award program and recent awards by the Commission.

WTO Trade Disputes Update

Thu, 08 Jul 2021 05:00:00 -0000

Both Australia and China initiate trade disputes under the WTO. The Kitchen is there to bring more details to you.

EU Adequacy Decisions on UK

Wed, 07 Jul 2021 05:00:00 -0000

The European Commission issues two Adequacy Decisions for personal data transfers to the UK. The Kitchen reviews the main points that go into a successful data transfer recipe.

Recent BIS Settlements

Tue, 06 Jul 2021 13:26:36 -0000

The Kitchen looks at recent Bureau of Industry and Security settlements with US companies for exporting without license.

BIS Update

Fri, 02 Jul 2021 05:00:00 -0000

Commerce’s BIS adds 5 to the Entity List – tackles China’s forced labor practices in Xinjiang. US Customs prohibits imports of silica-based products made with forced labor.

Canadian Sanctions on Belarus

Thu, 01 Jul 2021 05:04:00 -0000

Allied with the US, UK and the EU, Canada rolls out additional sanctions on Belarus, prohibiting financial services and dealing in property of the listed persons.

EU and UK Sanctions on Belarus

Wed, 30 Jun 2021 05:00:00 -0000

The UK and EU coordinate on Belarus sanctions and the Kitchen reviews what’s cooking in this area.

Iran Update

Tue, 29 Jun 2021 05:00:00 -0000

The Kitchen reviews the DOJ’s recent seizure of websites utilized by Iranian SDNs; UK issues guidance on financial restrictions under its sanctions on Russia.

EU Model Contract Terms for Data Transfer

Mon, 28 Jun 2021 05:03:00 -0000

The European Commission served up new and improved model contractual clauses for data transfers under the GDPR. Important dates are attached and the Kitchen took a look at this development.

New China Data Protection Law

Sun, 27 Jun 2021 18:43:06 -0000

China rolls out its new Data Protection Law. The Kitchen takes a peek at the main data points that are cooking in this significant legal area, ready to be served to companies in China, starting on September 1, 2021.

Update to EU Dual Use Regulation

Thu, 24 Jun 2021 05:00:00 -0000

The EU published a recast of its 2009 Dual Use Regulation. We look at some of the new or revised points that will now apply to EU exporters and providers of technical assistance when it comes to dual use items.

EU and US Trade Agreement on Boeing and Airbus

Wed, 23 Jun 2021 05:00:00 -0000

The EU and US reach an agreement on the ongoing WTO Boeing-Airbus dispute; FEMA eases up on some export restrictions of PPE.

China Anti-Foreign Sanctions Law

Tue, 22 Jun 2021 05:00:00 -0000

In this episode, we gather information on the new China’s anti-foreign sanctions law that appears to rank higher on the legal ladder that the previous Chinese government’s Unreliable Entity List and Blocking Rules, adding to the already opaque Chinese global trade landscape.

EU’s Mandate on Supply Chain Due Diligence

Mon, 21 Jun 2021 19:49:49 -0000

In this episode, The Kitchen looks at the upcoming EU’s mandatory supply chain due diligence Directive that will likely apply to all business operating in the European Union market.

America's Supply Chains

Fri, 18 Jun 2021 05:00:00 -0000

The Biden Administration’s 100 day review first set of reports under the “America’s Supply Chains” Executive Order are out and we take a look at what the findings and where is the White House planning to take them.

TikTok Sanction Changes

Thu, 17 Jun 2021 05:00:00 -0000

Staying local, the Kitchen reviews the recent Executive Order that ended TikTok and WeChat restrictions, but introduced new ones.

Boycott Sanction and the UAE

Wed, 16 Jun 2021 05:00:00 -0000

Looking at the developments in the boycott sanctions area, the Kitchen takes a look at the recent law in the UAE in regards to ending its boycott practices as to Israel.

OFAC and Burma

Tue, 15 Jun 2021 05:00:00 -0000

In this episode, the Kitchen checks into the ingredients of OFAC’s new general license for Burma and how did the UK amend its defense and military items open general export licenses.

Executive Order on Chinese Companies

Mon, 14 Jun 2021 13:53:01 -0000

The Kitchen examines a new Executive Order that aims to control securities holdings in certain Chinese companies that are part of the military-industrial sector in the PRC. The new Non-SDN Chinese Military-Industrial Complex Companies List replaces the former CCMC and broadens its scope.

NordStream 2 pipeline sanctions

Fri, 11 Jun 2021 05:03:00 -0000

This episodes looks at recent sanctions around the NordStream 2 pipeline construction project and brand new sanctions on Bulgaria’s public officials and their numerous entities.

Belarus and Airspace

Thu, 10 Jun 2021 05:04:00 -0000

Staying in Europe, the Kitchen review’s EU’s prohibition of Belarus from its airspace and airports. Next we review the recent collaboration between the US Customs and Nike in their efforts to fight the multi billion dollar counterfeits industry.

EU Blocking Statute Update

Wed, 09 Jun 2021 05:03:00 -0000

In this episode, we touch on the recent opinion by the EU’s Advocate General in regards to the EU’s Blocking Statute that runs up against US sanctions on Iran and Cuba.

Biden Adminstration Executive Order on Cybersecurity

Tue, 08 Jun 2021 05:08:00 -0000

The Kitchen looks into the recent Executive Order that aims to strengthen cybersecurity in the US government and private sectors.

OFAC Amendments to TSRA License FAQs

Fri, 28 May 2021 05:06:00 -0000

The Kitchen follows OFAC’s amendment to TSRA license FAQs and what modifications to the US HTS did the US ITC put in place.

OFAC Amends Narcotics Sanctions Regulations

Thu, 27 May 2021 05:06:00 -0000

This episodes looks at OFAC’s amendments to the narcotics and kingpin sanctions regulations. Next we will look at the DOD’s request for a public comment, the deadline and how to submit.

US HTS Recommendations and EU Guidance on Myanmar

Wed, 26 May 2021 05:05:00 -0000

Staying local, the Kitchen looks at the US Harmonized Tariff Schedule changes that are being recommended by the USITC. We will then cover EU’s guidance on the new Myanmar sanctions.

The Luokong Temporary Injunction Ruling

Tue, 25 May 2021 05:08:00 -0000

In this episode, we cover Luokong’s temporary injunctive relief ruling and go over an update on the EU Dual Use Items regulation.

Honeywell and FLIR Settlements

Mon, 24 May 2021 11:25:40 -0000

In this episode, the Kitchen looks into the recent Honeywell and FLIR settlements with the US regulators.

Moneygram settlement; WTO Trade Cost Index database; UK National Security and Investment Act

Fri, 21 May 2021 05:04:00 -0000

The Kitchen reviews the recent Moneygram settlement with OFAC and introduces the WTO’s new Trade Cost Index database. We then touch on the new and far-reaching UK National Security and Investment Act.

EU moves forward with Brexit Adjustment Reserve; SAP Settlement, OFAC and DOJ

Thu, 20 May 2021 05:03:00 -0000

This episode takes a look at EU’s declaration that it is moving forward with the Brexit Adjustment Reserve. We also touch on the recent SAP settlement with the US government in connection with the US sanctions regime.

UK and EU Sanctions on Myanmar

Wed, 19 May 2021 05:04:00 -0000

The Kitchen continues its coverage of the Myanmar/Burma sanctions. This episode looks at the UK sanctions on this country and also an update from the EU in this regard.

Russia Restrictions on Corporate Disclosures; OFAC updates Somalia sanctions

Tue, 18 May 2021 05:05:00 -0000

In this episode, we will touch on new Russia’s Restrictions on Corporate Disclosures; and OFAC’s updates to Somalia sanctions.

UK Anti-corruption sanctions program; UK guidance to export licenses

Mon, 17 May 2021 18:35:00 -0000

Today we will visit the UK and take a look at the new UK anti-corruption sanctions program and the UK guidance to certain export licenses.

Burma Sanctions Update

Thu, 13 May 2021 05:01:00 -0000

In this episode, we look at the recent EU and US sanctions on Burma, following the country’s violent military coup and resulting human rights abuses and violations.

Sudan Sanctions Update

Wed, 12 May 2021 05:01:00 -0000

This episode looks at recent changes to the US Sudan sanctions and an OFAC settlement that came about from Iranian Sanctions and doing business with a company there.

Ukraine Import Bans on Russia

Tue, 11 May 2021 05:01:00 -0000

We go to Ukraine and look at the recent step up of Ukraine’s import ban on Russia-made products. After that, we review the EU’s new guideline on the upcoming “Local Operator” requirement on “distance sellers” under EU’s market surveillance regulations.

UK Guidance on Military Exports

Mon, 10 May 2021 05:03:00 -0000

In this episode, we touch on the recent guidance issued by the UK’s export controls unit that concerns military and controlled technology exports. Next, we look at the Commerce Department’s addition of Chinese “supercomputing” companies to the BIS List.

Russia Sanctions Update

Fri, 07 May 2021 05:02:00 -0000

Today, we review recent changes and additions to the US government sanctions on Russia.

Boycotts and Maximum Penalties

Thu, 06 May 2021 13:58:22 -0000

This episode takes a quick look at changes of OFAC’s Boycott List, removing the UAE and the annual update of OFAC’s maximum civil penalties.

EU: Report on Predicted COVID-19 Impact on EU Trade

Wed, 27 May 2020 19:00:00 -0000

The European Commission published a report dated April 17, 2020 that details the impact that the corona virus is expected to have on EU trade. According to the Commission’s new release, the COVID-19 crisis will is anticipated to result in a decline of both EU exports (decline of 9.2%) and EU imports (8.8% decline) this year alone. The numbers are based on the estimated decline in GDP worldwide. The temporary shutdown of businesses and travel restrictions globally will combine to leave a decline in economic output, global trade, investment and general household spending. The Commission notes that “while there is a wealth of forecasts on GDP growth in 2020, there is a limited range of work done on trade projections for 2020, in particular for EU trade.”

You may have heard of the 1MDB scandal and the subsequent investigations and government protests that resulted in the country. Jho Lo appears to still be on the run, although he did reach a settlement with the US DOJ and Malaysia is seeing some return of the misappropriated funds. Recently, Malaysian Securities Commission issued an annual report, finding that only 59% of Malaysian listed companies have anti-corruption policies in place and even those, for the most part, needed to be beefed up. For more on this, and the Commission’s plans forward, see a news article here. If you are considering doing business with Malaysia, some official sources of information might be of assistance.

Silvia Surman summarizes these reports in this episode of the Compliance Kitchen.

CCPA – GDPR Comparison, ETIAS Registration for EU Travel

Thu, 07 May 2020 20:00:00 -0000

Stop by for a quick visit on CCPA and GDPR and how to register for your future EU travel, when we can hopefully travel again.

OFAC – Reporting of Rejected Transactions, Thoughts on Licensing Agreements

Wed, 06 May 2020 20:00:00 -0000

Listen is on the WTO’s prediction of global trade trends vis-a-vis COVID-19, some points to think about when looking at licensing agreements and how to file rejected transactions reports with OFAC.

Covid-19 and Global Trade

Tue, 05 May 2020 20:00:00 -0000

In this podcast episode, we take a look at recent import and export developments in the US and the EU, plus one update on anti-trust in response to the corona virus pandemic.

March/April OFAC Actions Update

Mon, 04 May 2020 20:00:00 -0000

Sylvia Surman returns in the Compliance Kitchen. In this episode, she discusses the update on some of OFAC’s recent SDN and sanctions activities. We will look at North Korea, Russia, Iran and Venezuela.

Compliance Kitchen-Mid Week Update, November 13, 2019

Thu, 21 Nov 2019 06:00:00 -0000

Silvia Surman is back cooking in the Compliance Kitchen. In this episode, listen in a quick update from the last week. Highlights include the recent EU-Singapore Trade Agreement, OFAC enforcement actions, OFAC compliance framework guidance, EU’s position on Turkey’s hydrocarbons drilling in the Mediterranean, EU dual-use exports report and more.

Into the Compliance Kitchen-DOJ Settlement, South Korean steel imports and more

Thu, 14 Nov 2019 06:00:00 -0000

Welcome to the Compliance Kitchen. Host Silvia Surman created it for those who want to “see what’s cooking” in the never-boring worlds of corporate compliance, white collar crime and global trade. We hope that our selection of topics will be of interest and that official resources will be easier to locate. We also hope that you will feel comfortable in the Kitchen and read on, finding it enjoyable. In today's episode Silvia catches up recent developments and news in the area of trade sanctions. We touch on two DOJ settlements, a new South Korean steel exports requirement and an annual report of US services exports.

Additional Resources

ComplianceKitchen.com

Just for the record, nothing in the Kitchen is to be considered a legal or professional advice and you may not use our information as such.

Introduction to the Compliance Kitchen

Wed, 13 Nov 2019 06:00:00 -0000

In this introductory episode, Compliance Kitchen host Silvia Surnam welcomes you to "See What's Cooking" in the Compliance Kitchen. The Compliance Kitchen was launched after many moons of texts, calls, chats and coffee outings that went something like this:

Hey, can my friend call you to see what you think about the Russia and Iran sanctions?
Where would you find support for that export license requirement? Can I call you?
Do you have a minute? This compliance lawyer told me that an Executive Order is a suggestion of what a law could be, not an actual law. Is that true?
So if we are not a US company, we can trade with Cuba, right?
What are secondary sanctions?
Say, any chance you would know if facilitation payment was more specifically set (dollar amount, for example) in Mexican anti-corruption law?
What’s a UBO?
This GDPR thing, that’s just for Europe, right? And we are Safe Harbor certified, so it doesn’t even apply to us – can we chat?
At a coffee shop one morning: So, what’s cooking in compliance today?

And so the Compliance Kitchen was born. It is here for those who want to “see what’s cooking” in the never-boring worlds of corporate compliance, white collar crime and global trade. We hope that our selection of topics will be of interest and that official resources will be easier to locate. We also hope that you will feel comfortable in the Compliance Kitchen and read on, finding it enjoyable.

Just for the record, nothing in the Compliance Kitchen is to be considered a legal or professional advice and you may not use the information as such.