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Are you rubbing elbows with criminals?
When OFAC designates someone a specially designated national, or SDN, it’s not a warning label. It’s a legal wall.
Every asset that party has anywhere in U.S. jurisdiction, or in the hands of a U.S. person, is frozen. Every U.S. person is barred from transacting with them, directly or indirectly.
<...U.S. District Judge Nicholas Garaufis has rejected the Justice Department’s request to drop the remaining bribery and obstruction of justice charges against executives connected to Indian billionaire Gautam Adani’s conglomerate, and this ruling deserves attention well beyond the Adani matter itself. It’s a rare and pointed example of a federal court refusing to simply ac...
Part 1 of this series walked through the settlement terms and the sheer range of violations DDTC documented against BAE Systems, spanning unlicensed technical data exports, unauthorized defense services, agreement mismanagement, and documentation failures. In Part 2, we focus on what actually caused all of this, because DDTC’s charging letter is unusually candid about ro...
If your organization does not yet have a written AI Acceptable Use Policy, I can tell you exactly what is happening inside your walls right now: employees are already using AI tools, whether you have authorized it or not. They are pasting documents into chatbots to summarize them, asking generative AI to draft correspondence, running research queries, and increasingly re...
Part 1 of this series laid out why the risk landscape around generative AI, confidentiality exposure, hallucination risk, and vendor risk, makes a written AI Acceptable Use Policy an urgent priority rather than a nice-to-have. In Part 2, I want to walk through what actually needs to be in that policy for it to function as a real governance tool rather than a document nob...