Compliance into the Weeds BAT Sanctions Enforcement Action
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 and looking for some hard-hitting insights on sanctions compliance. Look no further than Compliance into the Weeds!
Tom Fox and Matt Kelly dive into the recent enforcement action against British American Tobacco (BAT) for violating North Korean sanctions. After years of evading sanctions and funneling over $630 million, regulators have imposed the maximum penalty. Join the podcast to understand the scheme enacted by BAT and the consequences of their actions. They also discuss the need for clarity around who is responsible for ensuring compliance with OFAC and the Justice Department for the next 5 years. With potential penalties looming, the consequences senior management could face, and the extent of compliance commitments expected of BAT, this is a case you want to take advantage of. Listen to Tom and Matt make sense of this perplexing case and what it means for companies in countries like North Korea.
Key Highlights:
· Sanctions enforcement on British American Tobacco
· The North Korean Scheme of British American Tobacco
· British American Tobacco's Sanctions Compliance Penalty and Requirements
· Legal implications of BAT's North Korea joint venture
Notable Quotes:
“I almost think we should just name this series, ‘the hits just keep on coming’ as sanctions is the new FCPA.”
“This is a long-running, complicated scheme involving the highest levels of BAT knew this was going on to evade sanctions risks.”
“Short of Activision Blizzard, this case strikes me as 1 of the most egregious that we have seen in any form of trade control, export control, trade sanctions, FCPA, or other major corporate white collar.”
“They talk about how BAT and its subsidiaries knew full well that US sanctions said you can't do business with North Korea; they were upset over how BAT publicly announced it.”
Resources
Matt
Blog Post in Radical Compliance
Tom
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