Corruption, Crime & Compliance

Featured Articles:

General

22 Apr, 2024

BIS Emphasizes Need for Reinvigorated Due Diligence Efforts by Exporters

Remarks given by Commerce Secretary Gina Raimondo and Undersecretary Alan Estevez during the 2024 Policy Update Conference sponsored by the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) emphasized the need for organizations to enhance their due diligence efforts to prevent the diversion of restricted commodities to U.S. adversaries, including, but not limited to, the Russian Federation and the Islamic Republic of Iran. ...
General

21 Apr, 2024

SCG Plastics Pays OFAC $20 Million to Resolve Violations of Iran Sanctions Program

OFAC is capable of extending a long-arm of enforcement, reaching sometimes non-U.S. companies that may “cause” another company to violate U.S. Sanctions laws. If you need to find an example of this long reach, look no further than last week’s OFAC settlement with SCG Plastics (“SCG”), in which SCG, a Thailand company, which sells plastic resins, agreed to pay $20 million for violations of the...
General

18 Apr, 2024

DOJ Takes Aim At Apple’s Dominance Over Smartphones

The Justice Department has a long and rich history of targeting dominant companies using antitrust monopolization tools — looking back to the 1980s, it was AT&T; in the 1990s, it was Microsoft; and in 2023, DOJ has brought a monopolization case against Google; and meanwhile the FTC filed monopolization cases against Facebook and Amazon. DOJ has now turned to Apple and its dominance in the...
General

17 Apr, 2024

DOJ, Commerce and Treasury Issue JCN on Foreign Person Liability for Sanctions and Export Controls Violations

As DOJ, OFAC and BIS ramp up sanctions and export controls enforcement, they have continued to provide important compliance guidance. You have to give the enforcement agencies credit — on the one hand, they regularly warn of the coming enforcement storm and aggressive push against companies and individuals; and on the other hand, they provide significant compliance guidance. Over the last five years, DOJ, OFAC...
Podcasts

14 Apr, 2024

Episode 317 — Deep Dive into Trafigura’s FCPA Settlement

On the heels of the Gunvor FCPA settlement for $661 million, DOJ announced its settlement with Trafigura, the latest commodities trading company to fall under DOJ’s FCPA Sweep against the industry. Trafigura joined the list of international commodity trading companies to suffer FCPA enforcement actions — Vitol, Sargeant Marine, Glencore, Freepoint, and Gunvor. DOJ’s corporate resolutions are connected to individual prosecutions and guilty pleas of...

22 Apr, 2024

BIS Emphasizes Need for Reinvigorated Due Diligence Efforts by Exporters

Remarks given by Commerce Secretary Gina Raimondo and Undersecretary Alan Estevez during the 2024 Policy Update Conference sponsored by the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) emphasized the need for organizations to enhance their due diligence efforts to prevent the diversion of restricted commodities to U.S. adversaries, including, but not limited to, the Russian Federation and the Islamic Republic of Iran. ...

General

21 Apr, 2024

SCG Plastics Pays OFAC $20 Million to Resolve Violations of Iran Sanctions Program

OFAC is capable of extending a long-arm of enforcement, reaching sometimes non-U.S. companies that may “cause” another company to violate U.S. Sanctions laws. If you need to find an example of this long reach, look no further than last week’s OFAC settlement with SCG Plastics (“SCG”), in which SCG, a Thailand company, which sells plastic resins, agreed to pay $20 million for violations of the...

General

18 Apr, 2024

DOJ Takes Aim At Apple’s Dominance Over Smartphones

The Justice Department has a long and rich history of targeting dominant companies using antitrust monopolization tools — looking back to the 1980s, it was AT&T; in the 1990s, it was Microsoft; and in 2023, DOJ has brought a monopolization case against Google; and meanwhile the FTC filed monopolization cases against Facebook and Amazon. DOJ has now turned to Apple and its dominance in the...

General

17 Apr, 2024

DOJ, Commerce and Treasury Issue JCN on Foreign Person Liability for Sanctions and Export Controls Violations

As DOJ, OFAC and BIS ramp up sanctions and export controls enforcement, they have continued to provide important compliance guidance. You have to give the enforcement agencies credit — on the one hand, they regularly warn of the coming enforcement storm and aggressive push against companies and individuals; and on the other hand, they provide significant compliance guidance. Over the last five years, DOJ, OFAC...

Podcasts

14 Apr, 2024

Episode 317 — Deep Dive into Trafigura’s FCPA Settlement

On the heels of the Gunvor FCPA settlement for $661 million, DOJ announced its settlement with Trafigura, the latest commodities trading company to fall under DOJ’s FCPA Sweep against the industry. Trafigura joined the list of international commodity trading companies to suffer FCPA enforcement actions — Vitol, Sargeant Marine, Glencore, Freepoint, and Gunvor. DOJ’s corporate resolutions are connected to individual prosecutions and guilty pleas of...

General

10 Apr, 2024

Lessons-Learned from the Trafigura FCPA Settlement (Part III of III)

The Justice Department is rightly trumpeting its successful sweep of the commodities trading industry. DOJ’s success is reflected in its six separate corporate resolutions and 20 individual convictions, resulting in over $1.7 billion in penalties. Companies in the global commodities trading industry should take heed of DOJ’s focus. Every significant player in the industry, if not under investigation, should audit and review their operations. Those...

General

9 Apr, 2024

Trafigura’s Bribery Scheme: Clandestine Meetings, 3rd Parties and Shell Companies (Part II of III)

Trafigura’s bribery scheme resembles the same schemes implemented by its significant competitors — Vitol, Glencore, Gunvor. At the core of the conduct, Petrobras and Brazilian government officials collected bribes in exchange for valuable contracts for Petrobras oil. The factual statement reflects DOJ’s extensive knowledge base in the international commodity trading industry — DOJ had access to several significant cooperating witnesses, including Petrobras officials and trader...

General

8 Apr, 2024

Trafigura Joins the FCPA Enforcement Club: Pleads Guilty and Pays Over $126 Million for Bribery Violations in Brazil (Part I of III)

Podcasts

7 Apr, 2024

Episode 316 — DOJ Announces New Whistleblower Program and Encourages Self-Disclosures

In a recent speech, on March 7, 2024, Deputy Attorney General Monaco announced that DOJ would be implementing in the next 90 days a new whistleblower program to reward reporting of criminal misconduct at both public and private companies. In particular DOJ will encourage reporting of potential violations of the Foreign Corrupt Practices Act (“FCPA”) and the recently-enacted Foreign Extortion Prevention Act (“FEPA”). AAG Monaco...

General

4 Apr, 2024

SEC Finally Issues Climate Change Disclosure Rules

Daniela Melendez, an Associate at The Volkov Law Group, rejoins us for a posting on the SEC’s new climate disclosure rules. Daniela can be reached at [email protected]. After months and months of deliberations and negotiations, the SEC finally issued its final rules for climate disclosures. The Enhancement and Standardization of Climate-Related Disclosures for Investor (“the final rule”). The SEC navigated a series of political landmines...

Featured Articles:

BIS Emphasizes Need for Reinvigorated Due Diligence Efforts by Exporters

SCG Plastics Pays OFAC $20 Million to Resolve Violations of Iran Sanctions Program

DOJ Takes Aim At Apple’s Dominance Over Smartphones

DOJ, Commerce and Treasury Issue JCN on Foreign Person Liability for Sanctions and Export Controls Violations

Episode 317 — Deep Dive into Trafigura’s FCPA Settlement

BIS Emphasizes Need for Reinvigorated Due Diligence Efforts by Exporters

SCG Plastics Pays OFAC $20 Million to Resolve Violations of Iran Sanctions Program

DOJ Takes Aim At Apple’s Dominance Over Smartphones

DOJ, Commerce and Treasury Issue JCN on Foreign Person Liability for Sanctions and Export Controls Violations

Episode 317 — Deep Dive into Trafigura’s FCPA Settlement

Lessons-Learned from the Trafigura FCPA Settlement (Part III of III)

Trafigura’s Bribery Scheme: Clandestine Meetings, 3rd Parties and Shell Companies (Part II of III)

Trafigura Joins the FCPA Enforcement Club: Pleads Guilty and Pays Over $126 Million for Bribery Violations in Brazil (Part I of III)

Episode 316 — DOJ Announces New Whistleblower Program and Encourages Self-Disclosures

SEC Finally Issues Climate Change Disclosure Rules

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