Compliance into the Weeds Fracht - The Bonkers Sanctions Case
The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to explore a subject more fully. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode, Tom Fox and Matt Kelly discuss a recent OFAC enforcement action against a Swiss-domiciled freight forwarding company, Fracht.
The case stands out for its complexity, involving a single, high-value transaction that exposed the company to significant sanctions risk through dealings with both Venezuelan and Iranian entities. Tom and Matt break down the compliance failures, the role of senior management, and the extensive remediation steps taken post-incident. This episode offers actionable lessons for compliance professionals on supply chain due diligence, the importance of compliance involvement in urgent deals, and the consequences of sidelining compliance functions.
Key highlights:
- OFAC Enforcement Details
- Anatomy of the Transaction
- Third- and Fourth-Party Risks
- Senior Management Involvement
- Compliance Failures & Supply Chain Visibility
- Remediation & Consequence Management
Key Takeaways for Compliance Professionals:
- Always involve compliance in high-value, urgent transactions.
- Ensure robust due diligence for all counterparties, including third- and fourth-party risks.
- Senior management must be accountable for compliance failures.
- Remediation should include policy updates, staff training, and ongoing oversight.
Resources:
Matt on Radical Compliance
Tom
A multi-award-winning podcast, Compliance into the Weeds was most recently honored as one of the Top 25 Regulatory Compliance Podcasts, a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred the Davey, Communicator, and W3 Awards for podcast excellence.
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