Category: General

3 Apr, 2024

Carrots and Sticks: DOJ’s Push to Incentivize Voluntary Disclosure of Corporate Misconduct (Part II of II)

DOJ has been on a public relations campaign to push a simple message for corporations: if companies learn of misconduct, companies should disclose such misconduct to earn valuable benefits. The quintessential question remains — should companies disclose misconduct to the Department of Justice or should the company remediate the misconduct and maintain its silence? DOJ’s campaign is intended to push companies to reconsider this balance...

General

2 Apr, 2024

DOJ Enters Whistleblower Sweepstakes — Plans to Implement Bounty Program (Part I of II)

The Securities and Exchange Commission has gained well-publicized traction through its formal whistleblower bounty program. Only a small portion of these whistleblower reports involve FCPA, anti-bribery allegations. Notwithstanding this fact, the SEC whistleblower program has been an unquestioned success. Given this example, it is not surprising that the Department of Justice recently announced its plan to create its own whistleblower bounty program. In a recent...

General

1 Apr, 2024

JP Morgan Fined $348 Million for Deficient Record-Keeping

Regulators with the Federal Reserve and the Office of the Comptroller of the Currency (“OCC”) have fined JP Morgan Chase & Co. a combined total of $348.2 million over the bank’s failure to monitor client trading activities between 2014 and 2023. The enforcement action is a testament to regulators’ emphasis on the importance of sound market conduct risk controls, to which diligent record-keeping remains paramount....

General

29 Mar, 2024

DOJ and CFTC Bring Charges Against Crypto Exchange KuCoin for AML and KYC Failures

On March 26, 2024, the U.S. Department of Justice (“DOJ”) unsealed an indictment against prominent cryptocurrency exchange KuCoin and two of its founders, Chun Gan and Ke Tang. The DOJ charged the exchange and its founders with conspiracy and substantive charges related to Bank Secrecy Act (“BSA”) violations and operating an unlicensed money transmitter business. These charges were filed in the Southern District of New...

General

27 Mar, 2024

Implementation of EU Directive on Whistleblowing 2019/1931 (Part I of II)

By: Daniela Melendez, Associate at The Volkov Law Group and Alex Cotoia, Regulatory Compliance Manager at The Volkov Law Group Since its enactment in 2019, the European Union (“EU”) Directive on Whistleblowing 2019/1931 (“EU Directive”) has required all 27 EU Member States to incorporate certain requirements pertaining to the protection of whistleblowers into their own bodies of national law. The EU Directive alloted 2 years...

General

26 Mar, 2024

OFAC Settles First Case in 2024: EFG, a Private Bank, Pays $3.7 Million for Sanctions Violations

OFAC is getting ready for a big year. While managing a comprehensive set of sanctions against the Russian Federation in response to its Invasion of Ukraine, OFAC has demonstrated its ability to maintain aggressive enforcement of existing sanctions programs. The Justice Department and OFAC are forging a new enforcement partnership — and 2024 will be a precedent-setting year. Stay tuned for more on this new...

General

25 Mar, 2024

LRN 2024 Program Effectiveness Report Underscores Importance of Values, Adaptation and Accountability

LRN continues to set the standard for ethics and compliance program research. Volkov Law is a supporter of, and advocate for, LRN’s research because it has consistently confirmed what we all know and believe — ethical companies perform better in the marketplace over the long run. It is an intuitive fact that employees respond better to values-based leadership than a rules-based environment and culture. Volkov...

General

21 Mar, 2024

The SEC’s Recent Action Against Crypto Exchange ShapeShift Lacks Guidance and Draws Internal Criticism

On March 5, 2024, the U.S. Securities and Exchange Commission (“SEC”) announced charges and a corresponding cease-and-desist order (the “Order”) with ShapeShift AG, a cryptocurrency exchange registered in Switzerland that previously operated out of Colorado. The Order notes that ShapeShift allowed its users to buy and sell certain crypto assets that are considered securities as defined in Section3(a)(10) if the Securities Exchange Act of 1934. ...

General

20 Mar, 2024

Gunvor’s Blockbuster FCPA Settlement: Lessons Learned and Trends (Part III of III)

The Department of Justice’s blockbuster FCPA settlement with Gunvor restores the credibility of DOJ’s pronouncements of DOJ’s commitment to aggressive FCPA enforcement. While I have questioned DOJ’s commitment to its corporate enforcement policy in recent high-profile settlements (ABB and SAP, in particular), DOJ’s Gunvor settlement of $661 million stands as the ninth largest FCPA settlement in history. DOJ’s settlement is proportionate to the misconduct and...

Category: General

Carrots and Sticks: DOJ’s Push to Incentivize Voluntary Disclosure of Corporate Misconduct (Part II of II)

DOJ Enters Whistleblower Sweepstakes — Plans to Implement Bounty Program (Part I of II)

JP Morgan Fined $348 Million for Deficient Record-Keeping

DOJ and CFTC Bring Charges Against Crypto Exchange KuCoin for AML and KYC Failures

Implementation of EU Directive on Whistleblowing 2019/1931 (Part I of II)

OFAC Settles First Case in 2024: EFG, a Private Bank, Pays $3.7 Million for Sanctions Violations

LRN 2024 Program Effectiveness Report Underscores Importance of Values, Adaptation and Accountability

The SEC’s Recent Action Against Crypto Exchange ShapeShift Lacks Guidance and Draws Internal Criticism

Gunvor’s Blockbuster FCPA Settlement: Lessons Learned and Trends (Part III of III)

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