Question: please help me done compliance report about the below article : Cosmetics company violated OFAC's North Koreasanctions By Richard L. Cassin | Friday, February 1,
please help me done compliance report about the below article :
Cosmetics company violated OFAC's North Koreasanctions
By Richard L. Cassin | Friday, February 1, 2019 at 9:28AM
Image courtesy of ELFThe Treasury Department's Office of Foreign Assets Control fined a California-based cosmetics company nearly $1 million for importing fake eyelash kits that contained materials from North Korea.
The imports by e.l.f. Cosmetics, Inc. (or ELF) violated OFAC's North Korea Sanctions Regulations.
ELF found the North Korea-sourced materials in 156 shipments of false eyelash kits that it bought from two suppliers in China. The total value of the tainted shipments was $4.4 million.
"Throughout the time period in which the apparent violations occurred, ELF's OFAC compliance program was either non-existent or inadequate," OFAC said.
About 80 percent of the false eyelash kits ELF bought from the two China-based suppliers contained materials from North Korea, OFAC said.
ELF could have been fined $40 million for the violations, OFAC said.
The fine was reduced to about $996,000 because ELF self disclosed the violations, cooperated with OFAC, and adopted an enhanced compliance program.
OFAC also said no one at ELF knew about the North Korea content, and the fake eyelash kits weren't a big part of ELF's business.
OFAC's January 31, 2019 Enforcement Information against e.l.f. Cosmetics, Inc. is here (pdf).
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Part 1: Recent Compliance Problem and Enforcement Action
A.Identify the industry in which the compliance problem occurred or was alleged to have occurred.
B.What is the non-compliant behavior? When did happen? What laws or regulations were allegedly not followed?
C.When did the regulatory agency and/or court take action on this behavior?
D.What penalties and punishments resulted from this behavior?
E.What steps will be taken by the company to prevent the behavior from happening in the future?
Part 2: My Opinions of the Recent Problem and Enforcement Action
What do you think about:
What happened?
The company's behavior,?
The government's interventions?
The impact on the industry?
The impact on consumers?
The impact on the public in general?
Part 3: My Opinions of the Role of Compliance in Business
A.Prior to this assignment, did you know the term GRC? After reading the websites listed in this assignment, what is your understanding of GRC today? Did your understanding change? How would you explain the term GRC and the role of compliance to your management team who are unaware of these terms? Does compliance impact all business functions, and if so, how?
B.Prior to this assignment, were you aware that compliance is becoming its own industry? Why do you think compliance is becoming a discrete industry?
C.What were some of the jobs from the jobs websites you visited? What were the salaries? Do you think a job like one of the listed jobs might be in your future after graduation? Why or why not? Why do you think compliance jobs pay high salaries? Identify at least 4 jobs by title and salary if given.
D.Assume you take a job after graduation that DOES NOT have 'compliance' in the job title. Do you think you will be required to perform compliance activities in that job? Stated another way, who do you think is responsible for compliance? Everyone in the company, or only those persons trained and certified in compliance?
E.What role to you see for compliance functions in the next 5 to 10 years in the U.S. legal environment of business?
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