Do business in countries facing US sanctions at your own risk. The US<br />Office of Foreign Asset Controls (OFAC) is aggressively pursuing violators who<br />circumvent its prohibitions on evasion and facilitation. In-house counsel<br />operating in countries and regions monitored by the OFAC should be wary<br />of engaging in advocacy or seeking to find a work-around to these controls.
More than half of US citizens live in states where medical cannabis is legal, and a large majority support wholesale legalization, yet the cannabis industry faces significant federal obstacles. The 2013 Justice Department “Cole memo” established a formal policy of not prosecuting legitimate cannabis retailers, but later federal clarifications severely limited the access of the cannabis industry to conventional banking.
Outsourcing company services that require sensitive data to third parties does not relieve your organization of liability. Far from it — entrusting sensitive data to a vendor can increase your risk of a data breach and drive up the associated costs of the fallout. However, if you conduct due diligence and verify that your vendor can handle confidential information with care, you bolster your company’s defense if a breach occurs due to the vendor’s negligence.