Our Insights

SAMLA, the Sanctions and Anti-Money Laundering Act of 2018, represents the United Kingdom’s establishment of an independent sanctions policy in preparation for Brexit at the end of 2020. The legislation’s sanctions provisions are now in force and the UK Foreign Office has already designated several sanctioned parties. While these initially...

The United States’ Caesar Syria Civilian Protection Act came into force in June, expanding the existing sanctions regime against the Assad regime. The legislation highlights oil and gas and construction sectors as potential targets and opens the door to expanded sanctions on third country nationals engaging with Damascus. PSA CEO...

Who Owns Your Third-Party? Why you should want to know.

Understanding who owns your third party is an increasingly important part of due diligence, and best practices are evolving towards obtaining more ownership information. An accurate understanding of the ownership of a counterparty can help identify risks such as:

Hidden...

As companies work to rebuild global supply chains, PSA examines the case of e.l.f. Cosmetics, Inc. and its fine for sanctions violations. The DOJ found that these violations occurred because of a “largely inadequate” compliance program. The individual unit cost of the items were low,  and only limited elements of...

Whistleblower response is an increasingly important part of every company’s compliance environment, with a growing list of countries around the world requiring whistleblower protocols. Whistleblower allegations demand special attention from a company’s decisionmakers and present a unique set of investigative challenges. Every company should have a robust process to respond...