Category: General

General

4 Jan, 2024

OFAC Bolsters Russian Oil Price Cap Record-Keeping Requirements in New Round of Sanctions

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has renewed its commitment to squeezing Russia’s oil proceeds, releasing updated guidance with enhanced attestation and record-keeping requirements for maritime shipping operators and other industries that participate in the transport of Russian oil. OFAC also announced sanctions against several firms operating in apparent violation of the Price Cap. The Price Cap Policy is...

General

3 Jan, 2024

Diligent Webinar 01/16—Elevating Ethics: A Deep Dive into Modern Slavery Regulations for Compliance Leaders

Join Diligent and The Volkov Law Group for a webinar on January 16, 2024 that explores the complexities of modern slavery and human rights compliance within the realm of third-party risk management. As organizations face heightened scrutiny and increasing expectations to uphold ethical standards, understanding and navigating the evolving legal landscape is paramount. Alexander Cotoia, Regulatory Compliance Manager at The Volkov Law Group will guide...

General

3 Jan, 2024

HHS-OIG Guidance — Practical Steps to Achieve Effective Compliance (Part III of III)

Within the specific element discussions in HHS-OIG’s Guidance, are important operational details and strategies for an effective compliance program.  GCPG provides important suggestions and innovations for consideration by all compliance professionals. Effective Lines of Communication The GCPG stresses the importance of an open line of communication between the compliance officer and entity personnel as a means to reduce potential fraud, waste and abuse.  To this...

General

23 Dec, 2023

Happy Holidays And Happy New Year!!

To all our clients, family, friends and colleagues, The Volkov Law Group wishes everyone Happy Holidays and Happy New Year! Our blog, webinar and podcast services will resume on January 3, 2024. In the meantime, we wish everyone peace, gratitude. joy and love!! Mike, Matt, Alex, Sam, Daniela and Ben!!

General

22 Dec, 2023

HHS-OIG Guidance — Chock Full of Compliance Best Practices and Strategies (Part II of III)

Board Oversight of the Compliance Program The GCPG cross-references the US Sentencing Guidelines board responsibility requirements of the organization’s compliance program, and provides that the board shall “be knowledgeable about the contents and operation of the compliance and ethics programs and shall exercise reasonable oversight” of the program. The board has to specifically oversee the compliance officer and the compliance committee, and “review[] information necessary...

General

20 Dec, 2023

HHS-OIG Issues Comprehensive Compliance Guidance that Underscores the Need for a Robust and Independent Compliance Function (Part I of III)

The health care industry has a rich history of commitment and innovation in developing effective compliance  programs.  Going back to the 1990s, HHS elevated compliance program requirements for healthcare companies. Many of these innovations translated into strategies that became essential to the compliance industry. For example, in the 1990s, HHS’ Inspector General (“HHS-OIG”) affirmatively pushed for separation of the legal and compliance functions, resulting in...

General

19 Dec, 2023

OFAC Reaches Settlement with Cryptocurrency Company CoinList for Violations of Ukraine/Russia Sanctions

Matt Stankiewicz, Partner at The Volkov Law Group, provides an update on the latest OFAC action against CoinList. Matt can be reached at [email protected]. On December 13, 2023, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) announced an enforcement action against CoinList Markets LLC (“CoinList”) for violations of the Ukraine-/Russia-Related sanctions.  Between April 2020 and May 2022, CoinList processed 989 transactions on behalf...

General

18 Dec, 2023

Biden Administration Issues New Guidance for Freight Forwarders

By: Daniela Melendez (Associate at The Volkov Law Group) and Alex Cotoia (Regulatory Compliance Manager) New guidance from the Biden Administration mandates that freight forwarders are responsible for complying with trade sanctions and export compliance. On December 11, 2023, the Biden Administration released a 10-page sanctions advisory (“advisory note”) detailing the critical role that freight forwarders occupy in maintaining compliant supply chains. The advisory note...

General

15 Dec, 2023

Nasdaq Settles Iran Sanctions Violations for Pennies on the Dollar, Thanks to Voluntary Disclosure

When it comes to OFAC sanctions violations, honesty is the best policy. Promptly and voluntarily disclosing violations upon their discovery can pay serious dividends. So was the case for Nasdaq, Inc., which this week settled Iran sanctions violations in what could have been a $458 million OFAC penalty, for just $4.04 million, less than 1% of the applicable statutory maximum.  For those who view compliance...

General

13 Dec, 2023

Lessons Learned from Binance’s Criminal Settlement (III of III)

Matt Stankiewicz, Partner at The Volkov Law Group, finishes his series on Binance by providing key takeaways for AML compliance programs. Matt can be reached at [email protected]. Binance’s $4.3 billion fine is one of the largest penalties the DOJ has ever obtained from a corporate defendant.  Furthermore, its founder and CEO Changpeng Zhao (“CZ”) was also personally subject to a fine, amounting to $150 million. ...

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