Sanctions Compliance Failures: Lessons from Harman International and Interactive Brokers

Compliance into the Weeds

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. Seeking insightful perspectives on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss two recent OFAC enforcement actions involving Harman International and Interactive Brokers and the lessons they provide for compliance professionals.

Tom and Matt delve into the facts of both cases, finding under-resourced sanctions compliance programs in both companies. They highlight key issues, including inadequate personnel, misconfigured compliance tools, and a failure to conduct proper risk assessments. Despite self-disclosure and cooperation, both companies faced significant fines and were required to implement extensive remediation measures. The discussion highlights the growing importance of robust sanctions compliance programs in mitigating risks and preventing enforcement actions.

Key highlights:

• Sanctions Enforcement Cases Overview
• Harman International’s Compliance Failures
• Interactive Brokers’ Compliance Issues
• Lessons and Final Thoughts

Resources:

Matt Kelly in Radical Compliance

Tom

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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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