Sanctions Compliance Program – Management Commitment

Management Commitment means that senior management ensures the organization’s compliance with applicable sanctions programs by promoting a “culture of compliance” within the organization. This means that senior managers ensure that employees are aware of their responsibilities, inspire them to be compliant, and allocate adequate resources to enable the organization to be compliant.

Key Takeaways for Senior Management and Compliance Personnel from the Dan Bunkering Verdict

The verdict against Dan Bunkering, Bunker Holding, as well as the chairman of Dan Bunkering and CEO of Bunker Holding, is monumental not only because it is a rare example of a criminal conviction for EU sanctions compliance failures, but because it confirms the scope and expectations for what it means to comply with EUContinue reading “Key Takeaways for Senior Management and Compliance Personnel from the Dan Bunkering Verdict”

How should Nordic Banks and Companies React to the new US Russia Sanctions?

On April 15, 2021 the Biden administration announced a broad set of measures to combat malaign activities of the Rusisan government against the United States.  Some of these measures are very targeted and others create a broad structure for future sanctions that could have harsh consequences for us in the Nordics.   While they complicate theContinue reading “How should Nordic Banks and Companies React to the new US Russia Sanctions?”