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Your Bank Is Not Your Sanctions Compliance Program
A payment that clears a sanctions screening is not a transaction that complies. The October 13, 2026 Treasury actions against Bank of America show what happens when a bank is the only control, and why every U.S. person in a payment chain carries its own OFAC liability.
Trade Compliance Due Diligence in M&A and Private Equity Transactions
What M&A buyers, private equity sponsors, and venture capital funds should review in customs, export controls, sanctions, CFIUS, and OISP due diligence.
The BIS Affiliates Rule Returns on November 10, 2026: What Exporters Need to Do Now
The BIS Affiliates rule returns November 10, 2026 with no grace period. What it covers, why filing a license early will not help, and what exporters should do now.
U.S. Sanctions and AI: A Practitioner's Guide.
A practitioner's guide to how U.S. sanctions reach advanced AI: when OFAC has jurisdiction, the SDN List and the 50 Percent Rule, comprehensive jurisdiction programs, the CMIC investment prohibition, model access and open weights, three enforcement cases, and the compliance steps that matter.
U.S. Export Controls and AI: A Practitioner's Guide
A practitioner's guide to how U.S. export controls reach advanced AI in 2026: the 3A090 chip controls, the AI Diffusion Rule that BIS never formally rescinded and that the GAO has now ruled remains in effect, the January 2026 opening for H200-class chips to China, model weights, deemed exports, and the compliance steps a company should take.