AML and corruption in trade controls compliance: investigation, enforcement and mitigation

The discovery of a sanctions or export control breach can trigger considerations of voluntary disclosure to OFAC or BIS in the United States, as well as disclosures to other regulators which could be mandatory.  An issue that is initially identified through sanctions and export compliance efforts could also implicate anti-money laundering or anti-corruption regulations, raising the potential for additional regulatory disclosures. 

In the event of investigations into sanctions or export control issues, compliance officers need to collaborate with the in-house legal team and/or external counsel to ensure the information is gathered in an appropriate way to ensure integrity of the investigation, and maintain legal privilege protection for the business.  Internal risk management functions – such as operational risk managers or internal auditors – may also need to be notified of the issue and involved in its investigation and remediation.

In this one-hour webinar David Stetson of Steptoe & Johnson LLP, a former senior lawyer at OFAC and a senior in-house sanctions lawyer at Goldman Sachs, and Wendy Wysong, a former Assistant US Attorney in Washington and Deputy Assistant Secretary for Export Enforcement in the Department of Commerce’s Bureau of Industry & Security (‘BIS’):

• discuss how to identify AML or bribery issues in monitoring sanctions and export control compliance;
• suggest how to deal with internal investigations to preserve legal privilege and compliance with data protection regulations; and
• discuss how to deal with competing priorities for self-reporting to various agencies.

Join us and find out what mitigating steps to take when sanctions and export control issues cross with suspicions of money laundering and/or corruption.