Category: Sanctions

Former George W. Bush aide says an Uzbek businessman hired him to lobby for US sanctions on a local business rival

AU.S. political strategist says an Uzbek businessman asked him to lobby for sanctions against a huge cement manufacturer owned by a political and business rival over the business’s alleged Russia links. Stephen Payne, a top partner in Texas lobbying firm Linden Strategies, says that at his Uzbek client’s behest, he briefed Congressman Wesley Hunt, a Texas Republican, last year about possible sanctions violations by the Uzbek cement company, known as the United Cement Group. Payne, a one-time aide to former President George W. Bush, said he and his staff didn’t urge any specific action, but left it to Hunt and…

Crackdown on Narcos Reveals Alleged Lithuanian Trafficking Group

Key Findings A leaked memo from the Colombian prosecutor’s office reveals an international police operation targeting a drug trafficking ring allegedly spearheaded by Rokas Karpis, who was previously sentenced in New Zealand for drug offences, and another Lithuanian named Virginijus Labutis.The leaked memo reveals law enforcement in Australia and Colombia believed the Lithuanian pair had led a failed operation to smuggle almost 1.5 tons of cocaine across the Pacific on a small sailboat seized in 2017.Labutis was arrested in Colombia in September last year and extradited to Lithuania, then sanctioned — alongside Karpis — by the U.S. three months later.OCCRP…

Belgium Blocked $270B Due To Russian Sanctions. Much of It Belongs to Unsanctioned Investors.

An attempt by JPMorgan Chase & Co. to convince Belgian authorities to release about $2.4 billion blocked by Russian sanctions collapsed in court last year, according to the verdict obtained by reporters. The funds owed to JPMorgan, the largest bank in the U.S., remain blocked in Belgium. That’s because they are transactions with the Central Bank of the Russian Federation, which the European Union sanctioned in 2022. The court case, which has not previously been made public, highlights a glaring problem with the sanctions regime imposed by Western countries on Russia following its full-scale invasion of Ukraine. Much of the…

Slapped With Sanctions, Georgian Oligarch Ivanishvili Brings Assets Home

In response to international sanctions, Bidzina Ivanishvili, the billionaire founder and honorary chair of Georgia’s ruling party, has transferred ownership of multiple companies from offshore jurisdictions to Georgia, shielding his assets from global economic exposure. In December, the U.S. sanctioned the powerful tycoon, who is widely seen as the country’s informal ruler, saying he was undermining Georgia’s democracy for the benefit of Russia. Critics accuse the governing Georgian Dream party of becoming increasingly authoritarian and aligned with Moscow, often pointing out that Ivanishvili made his fortune in Russia in the 1990s. On December 31 — just four days after he…

‘We Know No Borders’: How Kyrgyzstan Became a Hub for Sanctioned Car Exports to Russia

For a car dealership in a country under sweeping economic sanctions, Moscow-based Berg Auto Premium offers a surprisingly wide selection of luxury vehicles. A Rolls-Royce Cullinan, costing nearly $1 million? They’ve got it. A fresh Tesla Cybertruck? Also in stock. A prestigious Porsche Cayenne Coupé? No problem. “We know no borders,” proclaims the dealership’s website, which claims to have over 100 cars available, collectively worth nearly $17 million. In December, an undercover reporter from OCCRP’s partner IStories called the dealership to ask if she could buy a newly made Porsche 911 Turbo — a car that would presumably be hard…

OFSI Threat Assessment Reports

The reports listed here are published as part of a series of sector-specific assessments addressing threats and vulnerabilities relating to UK financial sanctions. This follows OFSI’s commitment under the Economic Crime Plan 2 to publish sectoral sanctions threat assessments, intended to assist stakeholders in key UK sectors as part of a broader risk-based approach to sanctions compliance. Financial Services Threat Assessment Report Article Credit: https://www.gov.uk/government/publications/ofsi-threat-assessment-reports

Countering Russian sanctions evasion – guidance for exporters

This guidance is intended to support UK exporters in understanding Russian circumvention practices and in reducing the risk of their business being targeted by those seeking to evade sanctions. While every effort has been made to ensure the accuracy of the information in this guidance, it does not constitute legal advice and cannot be relied upon as such. It remains the responsibility of UK businesses to fully determine the extent of their specific sanctions risk exposure, and to develop an appropriate set of safeguards and controls tailored to their particular circumstances.  Consulting the external screening databases indicated in this document…

UK to launch world first sanctions regime to snare people smugglers travelling upstreamhttnce-danske-bank

The UK will develop a new sanctions regime to cripple people smuggling crime rings and starve them of illicit finance fuelling their operations.  The UK will develop a new sanctions regime to cripple people smuggling crime rings and starve them of illicit finance fuelling their operations.  In a major speech tomorrow, the Foreign Secretary will reveal plans to bring forward legislation for a new sanctions regime targeting irregular migration and organised immigration crime to secure UK borders in a decade of national renewal.    As the world’s first standalone sanctions regime dedicated to targeting irregular migration and organised immigration crime,…

Prime Minister announces new sanctions and £35 million of emergency support for Ukraine as Russia continues to attack critical national infrastructure

The UK has provided £35 million of emergency support to help Ukraine repair its energy grid and support the most vulnerable through a third winter of war, the Prime Minister has announced today. It comes as the UK also reinforces its iron-clad support for Ukraine by launching fresh sanctions targeting Russia’s energy sector. Today’s sanctions target 20 shadow fleet ships carrying illicit Russian oil, including Ocean Faye, Andaman Skies and Mianzimu, which have each carried more than four million barrels of Russian oil in 2024. Key lynchpins in enabling the trading of Putin’s precious oil, 2Rivers DMCC and 2Rivers PTE…

UK Unleashes Sweeping Sanctions to Target Russia’s War Machine & Shadow Networks Across the Globe

The UK has escalated its pressure on Vladimir Putin, announcing its largest package of sanctions since May. This new wave targets the Kremlin’s sprawling web of military supply chains and the shadowy mercenary groups doing Moscow’s bidding from Ukraine to Africa. With these measures, the UK aims to choke off Putin’s lifelines, hitting Russia where it hurts most: its ability to sustain the prolonged—and increasingly desperate—war in Ukraine. In a statement that underscored the UK’s determination, Foreign Secretary David Lammy said, “Putin is nearly 1,000 days into a war he thought would only take a few. He will fail, and…

Sanctions and Evasion Updates: Insights from OCCRP

At OCCRP, we strive to shed light on the pressing issues surrounding sanctions and sanctions evasion. We are excited to share the latest stories from OCCRP and its partners, along with our efforts at the Global Anti-Corruption Consortium (GACC) to amplify their impact.‍Key Themes from Our ReportingRecent reporting exposed how: ‍ A Cyprus IntermediaryTogether with OCCRP, our partners from the Belarusian Investigative Center (BIC), Schemes (Ukraine), and Belsat (Belarus), uncovered how a mysterious Cyprus-based company with ties to a former Belarusian official is being paid millions of euros by the Belarusian government to facilitate its trade in potash through Russia’s…

UK sanctions Russian troops deploying chemical weapons on the battlefield

Russian troops involved in the abhorrent use of inhumane chemical weapons on the battlefield in Ukraine have been targeted by new UK sanctions. Russia’s Radiological Chemical and Biological Defence (CBR) troops and their commander have been sanctioned for the deployment of barbaric chemical weapons in UkraineUK calls out Russia’s flagrant violation of the Chemical Weapons Convention (CWC) and urges Russia to immediately cease all such activityaction continues the Foreign Secretary’s personal mission to target the full spectrum of the Kremlin’s malign activity through our arsenal of sanctionsRussian forces have openly admitted to using hazardous chemical weapons on the battlefield, with…

UK-linked firms suspected of busting Russia sanctions

The government is carrying out 37 investigations into UK-linked businesses for potentially breaking Russian oil sanctions – but no fines have been handed out so far, the BBC can reveal.The identities of the businesses are unknown but it is understood some are likely to be maritime insurance firms.The Treasury said it would take action where appropriate, but pointed to the complexity of the cases as a reason they take considerable time.But Sir William Browder, a longstanding critic of Russian President Vladimir Putin, said it was an “embarrassment” that there had not been a single prosecution or fine for companies investigated…

Art Market Loopholes Again Threaten U.S. Economic Integrity and National Security

Federal Indictment Charges Kremlin Allies with Money Laundering and Sanctions Evasion On September 5, the U.S. Department of Justice unsealed two criminal indictments charging dual U.S.-Russian citizens with multiple felonies for using art, antiques, and other methods to violate sanctions imposed after the 2022 illegal invasion of Ukraine—a scheme that also allowed the married couple to launder at least $1 million through the U.S. financial system. Dimitri and Anastasia Simes allegedly provided services to and received substantial benefits from sanctioned Russian individuals and entities, including Channel One Russia, the state-controlled television network, and oligarch Aleksandr Udodov. Anastasia, specifically, is charged…

UK announces new sanctions under Iran, Russia laws

LONDON, Sept 10 (Reuters) – Britain on Tuesday announced a new wave of sanctions, adding seven designations under its Iran sanctions regime and three under its Russia regime.Some of those sanctioned included firms and organisations with ties to the drone industries in Russia and Iran.The announcement came after U.S. Secretary of State Antony Blinken said Russia had received ballistic missiles from Iran and would likely use them in Ukraine within weeks.Alongside that announcement, made during a visit to Britain, Blinken said the U.S. would also impose new sanctions, including on airline Iran Air.France, Germany and Britain strongly condemned Iranian transfers…

US sanctions over 400 firms accused of aiding Russian war effort

The United States imposed new sanctions Friday on more than 400 entities accused of supporting Russia during its war with Ukraine. Announced the day before Ukraine’s Independence Day holiday, the sanctions focus on firms in Russia, Europe, Asia and the Middle East accused of helping Russia avoid U.S. sanctions and enabling its war in Ukraine, according to a Treasury Department press release. The Biden administration also added 123 firms to the U.S. export control list, which requires suppliers to obtain licenses prior to shipping items to the companies listed. Those added Friday included 42 Chinese firms and 63 Russian firms,…

UK – HMRC criminal investigation into alleged exports of perfume to Russia

In a civil judgment handed down earlier this week, it was revealed (at paragraph 63) that an individual, David Crisp, was arrested by HMRC on 10 October 2023 and electronic devices were seized. The allegation is that companies managed by Mr Crisp were knowingly exporting perfume to Russia in breach of the UK’s sanctions. As of the date of the judgment, HMRC had confirmed (at paragraph 69) that the criminal investigation remains ongoing but so far no charges have been made and Mr Crisp is no longer on bail. The judgment itself is of note for the Court removing Mr…

StanChart loses bid to cut US sanctions breach claims from UK lawsuit

Standard Chartered on Monday lost a bid to cut from a London lawsuit allegations that it broke U.S. sanctions against Iran in a more widespread way than it has previously admitted. More than 200 investors are suing Standard Chartered at London’s High Court for allegedly untrue statements about its sanctions non-compliance between 2007 and 2019. The lawsuit comes after the London-based bank agreed to pay $1.1 billion in 2019 to U.S. and British authorities over transactions which breached sanctions against Iran and other countries. The 2019 deal extended by two years a 2012 deferred prosecution agreement with Standard Chartered, under…

‘Sanctions hole’: how secretive routes supply Russia with western tech and consumer goods

Since Vladimir Putin’s invasion of Ukraine, the west has imposed thousands of sanctions on Russia, and handed it the dubious distinction of being the most heavily sanctioned country on Earth. Targeting everything from the finances of individuals to the major industries of its economy, international sanctions have aimed to isolate Russian consumers, with major brands such as Apple and McDonald’s ceasing their operations in the country. But two years on, Russia’s economy is showing surprising resilience and is forecast to grow faster than most of the world’s advanced economies, although experts say that it is unsustainable in the long term.…

New UK sanctions to crack down on Putin’s war machine

UK announces 50 new sanctions designations and specifications to degrade Putin’s war machine, in co-ordinated action with G7 partners to support Ukraine.  New targets include ships in Putin’s shadow fleet, institutions at the heart of Russia’s financial system and suppliers supporting Russia’s military production.   These new sanctions, announced while the Prime Minister attends the G7 Leaders Summit in Italy, will bear down on Russia’s ability to fund and equip its war machine and show the UK’s steadfast support for Ukraine. Today’s action includes the UK’s first sanctions targeting vessels in Putin’s shadow fleet, used by Russia to circumvent UK and…

New EU rules criminalising the violation of EU sanctions enter into force

As from 19 May, new rules to harmonise criminal offences and penalties for the violation of EU restrictive measures enter into force. The new rules will ensure that such violations can be criminally investigated and prosecuted in all Member States. They include a list of criminal offences related to the violation and circumvention of EU sanctions, such as for example: failing to freeze assets; breaching travel bans and arms embargoes; providing prohibited or restricted economic and financial services, transferring funds that should be frozen to a third party or providing false information to conceal funds that should be frozen. The…

US Department of Treasury Imposes Targeted Sanctions on Iran

The Department of the Treasury’s Office of Foreign Assets Control (OFAC) has announced targeted sanctions against multiple individuals and entities involved in Iran’s UAV (Unmanned Aerial Vehicle) program, steel industry, and automobile sector. The sanctions aim to disrupt Iran’s UAV production capabilities, particularly focusing on engine types powering Iran’s Shahed variant UAVs, which were utilized in the April 13 attack on Israel. These actions are directed towards individuals and entities facilitating Iran’s UAV production arm, including Kimia Part Sivan Company (KIPAS) and other Iranian UAV manufacturers. Additionally, OFAC is designating five companies across various jurisdictions involved in supplying component materials…

Still no fines as a result of 2022 Russian sanctions breaches

No fines for sanctions breaches have been levied as a result of the 2022 sanctions against Russia since its full-scale invasion of Ukraine, correspondence from the Foreign, Commonwealth and Development Office (FCDO) reveals. Letter from Minister Trevelyan relating to Russian sanctions, dated 28/03/2024Read the report [HTML]Download the report [PDF 525B]Evidence Session: The situation in Ukraine and the UK’s responseInquiry: Responding to illicit and emerging financeForeign Affairs CommitteeMinister of State at the FCDO, Anne-Marie Trevelyan, writes that she expects Government investigations into potential breaches of the UK’s financial sanctions, imposed on Russian individuals and organisations since the invasion, to come to…

US Sanctions Zimbabwe President for Corruption and Torture Against His People

Zimbabwe President Emmerson Mnangagwa was sanctioned by the U.S. Treasury’s Office of Foreign Assets Control (OFAC) Monday for corruption and severe human rights abuses, which include members of his administration facilitating acts of kidnapping and torture. In addition to Mnangagwa, the U.S. blacklisted 10 members of his government and their spouses under the the Global Magnitsky Program for corrupt practices to the detriment of their citizen’s human rights and well-being. The new measures replace an older set of sanctions against the Southern African state, which the Biden administration felt were too harmful to the Zimbabwe economy. “The United States remains…

Settlement Agreement between the U.S. Department of the Treasury’s Office of Foreign Assets Control and EFG International AG

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) today announced a settlement with EFG International AG, a Switzerland-based global private banking group. EFG has agreed to pay $3,740,442 to settle its potential civil liability for processing 873 securities transactions in apparent violation of the Cuban Asset Control Regulations, the Kingpin Act, and +Order 14024. The settlement amount reflects OFAC’s determination that EFG’s apparent violations were voluntarily self-disclosed and were non-egregious. Article Credit: https://ofac.treasury.gov/recent-actions/20240314_33

EU proposes sanctions on Chinese firms aiding Russian war effort

The EU is proposing to sanction companies in mainland China for the first time as part of its latest measures aimed at shutting down loopholes that allow Russia to route military technology via third countries to its weapons factories. Three companies in mainland China, as well as four in Hong Kong and one in India, are on a 91-page document of companies and individuals who EU member states want to add to a growing sanctions list before the second anniversary of Russia’s invasion of Ukraine. As the EU, the UK and US representatives prepare to meet in Brussels on Wednesday,…

UK warns of criminal sanctions evasion through artwork storage facilities

The National Crime Agency has issued an alert to artwork storage facilities, warning of potential criminal exploitation of the sector by individuals subject to Russia sanctions. With new individuals and entities being added to the sanctions list at frequent intervals, the alert highlights the need for the sector to conduct regular due diligence checks to understand any change in a client’s circumstances, or those of elites they may represent. High-net-worth individuals, such as Russian oligarchs hold art in specialist storage facilities for a range of reasons, including secure storage of art as an investment or as a store of value…

US and UK sanction senior Houthis over Red Sea shipping attacks

The US and the UK have imposed sanctions on four senior Houthi officials for their roles in supporting or directing attacks on commercial shipping in the Red Sea. Those targeted include Houthi defence minister Mohamed Nasser al-Atifi, commander of Houthi naval forces Muhammad Fadl Abd al-Nabi, coastal defence forces chief Muhammad Ali al-Qadiri and Muhammed Ahmad al-Talibi, described as the Houthi forces director of procurement. “The Houthis’ persistent terrorist attacks on merchant vessels and their civilian crews … threaten to disrupt international supply chains and the freedom of navigation, which is critical to global security, stability, and prosperity,” the US…

UK publishes two new Russia sanctions regulations and two new General Licences

On 14 December 2023, the UK Government introduced two regulations (The Russia (Sanctions) (EU Exit) (Amendment) (No. 4) Regulations 2023 and The Russia (Sanctions) (EU Exit) (Amendment) (No. 5) Regulations 2023) amending The Russia (Sanctions) (EU Exit) Regulations 2019 to impose further restrictions on goods, technology, and sources of funding that the UK Government considers could support Russia’s war against Ukraine. The majority of the amendments came into force on 15 December 2023; however a number will come into force on 26 December 2023 and 1 January 2024. Separately, on 15 December, the UK also designated Novikombank, which is now…

New unit to crack down on firms dodging Russian sanctions

Companies who are found to be dodging strict trade sanctions, including those imposed since the war in Ukraine, will face tougher penalties with the creation of a new Office of Trade Sanctions Implementation (OTSI). Industry and Economic Security Minister Nusrat Ghani is today [11 December 2023] announcing the creation of a new unit to crack down on companies dodging Russian sanctions. The OTSI will be responsible for the civil enforcement of trade sanctions, including those against Russia. The unit will help businesses comply with sanctions and investigate potential breaches, issuing civil penalties and referring cases to HMRC for criminal enforcement…

Council and Parliament reach political agreement to criminalise violation of EU sanctions

The Spanish presidency of the Council and the European Parliament concluded their negotiations for an EU law which introduces criminal offences and penalties for the violation of EU sanctions. This directive ensures that those who violate or circumvent EU sanctions will be prosecuted. This gains particular importance in the context of the Russian war of aggression against Ukraine. The law lays down that member states will need to define certain actions as criminal offences. These include: helping persons subject to EU restrictive measures to bypass a travel bantrading sanctioned goods and running transactions with states or entities which are hit…

Former Special Agent in charge of the New York FBI Counterintelligence Division sentenced to 50 Months for conspiring to violate U.S. Sanctions on Russia

A former Special Agent in Charge (SAC) of the FBI Counterintelligence Division in New York, was sentenced to 50 months in prison and ordered to pay a $40,000 fine for conspiring to violate the International Emergency Economic Powers Act (IEEPA) and to commit money laundering in connection with his 2021 agreement to provide services to Oleg Deripaska, a sanctioned Russian oligarch. According to court documents and statements made in court proceedings, Charles McGonigal, 55, of New York, New York, pleaded guilty in August. “Charles McGonigal helped advance the interests of a sanctioned Russian oligarch, breaking his oath to safeguard our…

UK cracks down on gold and oil networks propping up Russia’s war economy

Foreign Secretary announces 29 new UK sanctions targeting individuals and entities operating in and supporting Russia’s gold, oil and strategic sectors. new UK sanctions target 29 individuals and entities operating in and supporting Russia’s gold, oil and strategic sectorsthose sanctioned include Russia’s largest gold refiner and international networks propping up Russia’s gold, oil and finance industriesto date the UK has sanctioned over 1,800 individuals, companies, and groups under our Russia sanctions regimeTwenty nine individuals and entities operating in and supporting Russia’s gold and oil sectors have been sanctioned by the UK today [8 November]. New listings include both Russian oligarchs…

United States and United Kingdom Take Coordinated Action Against Hamas Leaders and Financiers

WASHINGTON — Today, U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) imposed its third round of sanctions targeting Hamas-affiliated individuals and entities since the October 7 Hamas terrorist attacks on Israel. This action designates key Hamas officials and the mechanisms by which Iran provides support to Hamas and Palestinian Islamic Jihad (PIJ). Today’s designations are coordinated with action by the U.K. and are aimed at protecting the international financial system from abuse by Hamas and their enablers. The U.S. Department of State is concurrently designating a leader of PIJ’s military wing. “The United States will continue to…

Cyprus Wing of Auditing Giant PwC May Have Breached Sanctions in Work for Oligarch

As Russian tanks rolled into Ukraine in late February 2022, staff at the Cypriot wing of international auditing giant PwC were rushing to tie up the sale of hundreds of millions of dollars’ worth of assets owned by Russian oligarch Alexey Mordashov. Like other pro-Kremlin billionaires, Mordashov — described by Forbes as Russia’s richest person in 2021 — was at risk of having his European assets frozen if authorities sanctioned him in response to the invasion. At PwC Cyprus, staff exchanged documents marked “URGENT” and “PLEASE APPROVE” as they prepared paperwork to sell Mordashov’s stake in German travel company TUI…

OFAC Sanctions Mexican and Colombian Nationals Involved in Sinaloa Cartel

On September 26, 2023, the United States Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned 10 individuals involved in illegal fentanyl, cocaine, and methamphetamine trafficking into the United States on behalf of Mexico’s Sinaloa Cartel. As we’ll explore below, one of those individuals controls an Ethereum address that was included as an identifier on his SDN List entry. Today’s actions represent a coordinated effort between OFAC, the Drug Enforcement Administration (DEA), the Government of Mexico’s La Unidad de Inteligencia Financiera, and the Colombia Counternarcotics Working Group. Who are the sanctioned individuals and what did they do?Nine of…

IRS investigating sanctioned Russian oligarchs’ use of South Dakota Trusts

U.S. authorities are investigating cases of Russian oligarchs evading sanctions by hiding assets in South Dakota trusts, an Internal Revenue Service agent told South Dakota Public Broadcasting. In 2021, ICIJ’s Pandora Papers investigation revealed the state had become a financial secrecy hub in the United States, due to a burgeoning trust industry courting millionaire and billionaire clients by promising privacy and wealth protection rivaling overseas tax havens. Special agent Tom Larson told SDPB that the agency had a team dedicated to uncovering assets belonging to sanctioned individuals stashing wealth in trusts through shell companies. “We’ve found that some of that…

FinCEN analysis reveals trends and patterns in suspicious activity potentially tied to evasion of Russia Related Export Controls

WASHINGTON—Today, the Financial Crimes Enforcement Network (FinCEN) issued a Financial Trend Analysis (FTA) on patterns and trends contained in Bank Secrecy Act (BSA) reporting on suspected evasion of Russia-related export controls. The BSA reports analyzed for this FTA were filed in response to previous joint Alerts on this topic and indicate almost $1 billion in suspicious activity. “Following Russia’s invasion of Ukraine, FinCEN and the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued two joint Alerts urging vigilance on the part of U.S. financial institutions for potential attempts by Russia to evade U.S. export controls,” said Acting…

Wise Payments Faces Scrutiny from UK Government Over Alleged Breach of Russian Sanctions

Wise Payments Limited (“Wise”), a UK-based financial services provider, is under scrutiny after an investigation by the UK Office of Financial Sanctions Implementation (OFSI) revealed potential violations of sanctions imposed on Russia. The sanctions in question stem from The Russia (Sanctions) EU Exit Regulations 2019 and are aimed at restricting certain Russian individuals, entities, companies, and their subsidiaries from accessing and using their assets. These measures were put in place in response to Russia’s actions, including its annexation of Crimea and its involvement in conflicts in Eastern Ukraine. The breach in question pertains to a cash withdrawal of £250 made…

U.K. Regulator Publishes 5 Top Advices to Ensure Banks and Fintech Adhere to Russian Sanctions Regime

BRITISH regulator the Financial Conduct Authority has published new advice on an adhering to the country’s sanctions regime. The authority “the unprecedented size, scale, and complexity of sanctions imposed by the UK Government and international partners since Russia’s invasion of Ukraine, has further increased our focus on firms’ sanctions systems and controls.” The FCA said it had been engaged in a substantial programme of work assessing the systems and controls relating to sanctions compliance for over 90 firms across a range of sectors. This has involved proactive assessments of firms’ controls, using a new analytics-based tool, as well as the…