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When Sanctions Fail: The Ovsiannikov Case and Why Enhanced Due Diligence Must Become a Compliance Standard
6. Vendor Due Diligence: 11.68%
Credit: Bacho Foto/Adobe Stock
In April 2025, the United Kingdom secured its first-ever criminal conviction for a breach of Russian sanctions — a milestone in the global enforcement landscape. But beneath the headline lies a far more pressing narrative: how a sanctioned Politically Exposed Person (PEP) was able to enter the UK, open a bank account, and launder funds through mainstream financial and non-financial institutions without detection.
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New York's Latest Cybersecurity Commitment
On Aug. 9, 2023, Gov. Kathy Hochul introduced New York's inaugural comprehensive cybersecurity strategy. In sum, the plan aims to update government networks, bolster county-level digital defenses, and regulate critical infrastructure.
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The DOJ's Criminal Division issued three declinations since the issuance of the revised CEP a year ago. Review of these cases gives insight into DOJ's implementation of the new policy in practice.
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