In “Navigating an Increasingly Complex Sanctions Landscape, Part 1: Today & Tomorrow” (14 July 2020, FCPA Compliance Report), Tom Fox features Eric Lorber and Adam Frey on sanctions. In the article, Adam and Eric discuss the current state of sanctions and what themes may inform the future. According to Eric, sanctions in the compliance ecosystem have a feedback loop, which “builds on itself. What do I mean by that? Over the last 15 or 20 years, you’ve seen really financial institutions in particular subject to enforcement activity by OFAC. This has led to most large financial institutions [investing] quite a bit of money and quite a bit of resources into beefing up their sanctions compliance programs.”
Looking to the future, Adam notes, “We are starting to see how connected everything is. The result is that you cannot look at your sanctions program in isolation. . . . That old adage, I hate to say it, but the ounce of prevention is worth a pound of cure.”
Read more in the FCPA Compliance Report. For additional information, tune into Eric Lorber and Adam Frey’s sanctions podcast series with Tom Fox here.