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Description: In 2021, OFAC has issued several key enforcement actions, including involving non-U.S. financial institutions and non-U.S. companies outside the financial industry. These enforcement actions show OFAC’s evolving view of its jurisdiction over non-U.S. entities and its application of sanctions requirements to new industries and sectors. The enforcement actions also highlight OFAC’s expectations for industry when developing and implementing a sanctions compliance program.
This webinar will provide an overview of key enforcement actions from 2021 and highlight certain takeaways for industry when enacting and maintaining a sanctions compliance program.
Presenter Bios
Sanjay Mullick has a broad range of experience providing counsel on export controls administered by the Department of Commerce Bureau of Industry and Security (BIS) under the Export Administration Regulations (EAR); the Department of State Directorate of Defense Trade Controls (DDTC) under the International Traffic in Arms Regulations (ITAR); and the Department of Energy’s rules on nuclear exports, as well as economic sanctions administered by the Department of the Treasury Office of Foreign Assets Control (OFAC). He also advises on compliance and enforcement matters concerning the Bureau of Customs and Border Protection (CBP) and foreign trade zones (FTZ).
Mr. Mullick advises companies, sponsors and investors on export controls and sanctions risk assessment in conjunction with investments, offerings and mergers and acquisitions. He also conducts internal investigations, handles voluntary self-disclosures, and designs and implements trade controls compliance programs. Mr. Mullick assists companies with navigating the export control aspects of software deployment, including global encryption controls, cloud computing, and offshore outsourcing. In addition, he counsels companies and financial institutions on compliance with economic sanctions, including considerations for market entry and implementation of corporate policies and procedures.
Carrie Schroll is a partner in the International Trade and National Security Practice Group in the Washington, D.C., office of Kirkland & Ellis LLP, focusing her practice in the areas of export controls (ITAR and EAR), trade and economic sanctions (OFAC), customs, national security reviews by the Committee on Foreign Investment in the United States (CFIUS), anti-boycott restrictions, anti-money laundering (AML) regulations, and compliance with the U.S. Foreign Corrupt Practices Act (FCPA).
She advises a diverse range of clients on international trade and FCPA due diligence in connection with corporate transactions, and has counseled clients in internal investigations related to compliance with economic sanctions, export controls, and anti-corruption laws. She also regularly assists clients in developing trade and anti-corruption compliance programs.
 | | Practice Areas: | | Banking & Finance Law, Business Organizations & Contracts, International Law & Global Trade | | | Online Media Type: | | Audio | | | Production Date: | | 12/13/2021 | | | Level: | | Intermediate | | | Category: | | Standard | | | Duration: | | 1 Hours, 1 Minutes | | | Online Format: | | On Demand | | | Course Type: | | Public |
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| | • | Sanjay J. Mullick, Esq. - Kirkland & Ellis LLP | | • | Carolyn Schroll, Esq. - Kirkland & Ellis LLP |
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