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In a recent enforcement action, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) reported on a matter involving inadequate automated due diligence. The case involved Cobham Holdings, Inc. violating Ukraine-related sanctions regulations. Cobham was punished for relying solely on automated due diligence, which failed, and did not have other layers of protection in place. (Read the Full Report).

OFAC found the violation to be non-egregious, but the action was preventable had Cobham Holdings, Inc. performed adequate diligence.

Now is a good time to review the effectiveness of your compliance program. Make sure your processes are risk-based and adequate to avoid government investigations and charges.

1. Identify Risk: Whether you are entering into a new market or are continuing to work in an existing high-risk area, identify any risks facing your operations and tailor your compliance program to meet the challenges.
2. Create a Plan: Develop a multi-level approach to address risk. Relying solely on automated screening is not sufficient to meet FCPA and other Anti-Bribery requirements.
3. Regularly Review: Threats don’t remain constant, often new ones arise throughout the year. Your compliance program must continually evolve.

 We stand ready to help you develop a compliance program that is risk-based and effective.