In March, there was a good deal of consternation in the general press trying to understand news that President Trump had overruled the actions of the Office of Foreign Assets Control (“OFAC”) to impose additional sanctions on North Korea. Beside the oddity of a President overruling actions by a part of the Executive branch after

Canada

Canadian anti-corruption law is now clear, facilitation or “grease” payments to foreign public officials are illegal. There used to be a gray area – some Canadian companies did not know how to approach the small payments requested by low-level officials to speed up routine government functions and Canadian compliance managers wasted much time guessing

Canada

On September 22, 2017, Canada did something it has not done in a while – Canada imposed unilateral economic sanctions and asset freezes against 40 officials in the Venezuelan Maduro regime.  A new list of designated persons (Canada’s term for sanctioned persons) was publicly releases – the persons against whom the unilateral economic sanctions,