Members of CRA’s team were hired to identify and remediate potential gaps in the compliance policy of a global payment processor. The engagement involved a review of historical transactions to locate potential violations of U.S. and global sanctions. A technical examination of payment alert systems and in-person interviews with staff were conducted to assess all aspects of the client’s compliance infrastructure. The team identified and remediated a gap that had allowed parties sanctioned by OFAC access to the payment platform.
How PE firms can prepare for the DOJ’s Section 8 crackdown on interlocking directorates across portfolio companies
In this article, published in Private Equity Law Report, CRA consultants discuss the renewed push by the US Department of Justice (DOJ) and the Federal Trade...