On December 19, 2018, the SEC announced settlements with two former senior executives of Panasonic Avionics Corporation. In April 2018, Panasonic Avionics settled FCPA charges with the Justice Department and the SEC and agreed to pay $280 million. (Here) Paul Margis (Here), the former CEO, and Takeshi Uonaga (Here), the former CFO, agreed to pay $75,000, and $50,000 respectively, to settle books and records and...
The Treasury Department’s Office of Foreign Asset Control (OFAC) rarely backs down. Recently, in response to significant ownership and governance changes, OFAC removed three Russian companies, EN+ Group (EN+), UC Rusal plc (Rusal), and JSC EuroSibEnergo (ESE) from the sectoral sanctions list. (Here). OFAC’s decision to remove the three companies capped the efforts of Russian oligarch, Oleg Daripaska, to modify his ownership and control of...
This is my favorite topic. New trends come and go in the compliance field, while effective solutions and strategies slowly but surely take hold. Eventually, an effective compliance practice or strategy becomes a “best practice,” or an “industry standard.” To those who complain that ethics and compliance is a profession riddled with amorphous standards or vague “guidance” that lacks discipline, my response is that such...
Webinar: 2018 Review of OFAC Sanctions Enforcement and Compliance Trends January 15, 2019, 12 Noon EST Sign Up HERE The Department of Treasury’s Office of Foreign Asset Control had a busy year — first imposing the Russian Oligarch Sanctions Program and re-imposing the Iran Sanctions Program; and in the second-half of 2018, OFAC resumed its steady enforcement of sanctions. Join Michael Volkov, CEO of The...
The Department of Treasury’s Office of Foreign Asset Control (OFAC) has steadily expanded its influence in the enforcement landscape. Global companies now face a complex regime of sanctions that require careful navigation. As the U.S. government expands its reliance on sanctions to influence foreign actors and advance foreign policy interests, global companies have to design and implement robust trade compliance programs. In recognition of this...
In 2018, ethics and compliance professionals continued to innovate and push for compliance program enhancements. In response to growing demand, compliance industry vendors helped to implement new and innovative tools for use in compliance programs. In this episode, Michael Volkov reviews ethics and compliance trends and developments during 2018 and outlines predictions for the upcoming year.
Here we go – another year, another set of predictions. Who knows whether they will come true? Actually, I went back and read my annual prediction posting for 2018 and 2017, respectively. Some things I called correctly, and others I missed the mark on. One consistent error – the Wal-Mart FCPA case would be resolved. So this year, I am employing reverse psychology. The Wal-Mart...
Happy New Year! Another year is in the books for FCPA enforcement and compliance. The headline for this past year (like many other years) is/was – The more things change, the more they stay the same. FCPA enforcement is bipartisan and immune from political winds. I may live to regret this assertion. Whether DOJ is under Republican or Democrat control, FCPA enforcement will continue. DOJ’s...
The Justice Department and the Securities and Exchange Commission had another strong year in FCPA enforcement. The numbers for 2018 tell a compelling story. Corporations Individuals Declinations Fines/Penalties DOJ 5 26 4 $950 million SEC 14 4 NA $380 million Total 19 30 4 $1.33 billion In this episode, Michael Volkov reviews FCPA enforcement for 2018 and outlines interesting trends and developments.
Webinar: Review of 2018 FCPA Enforcement January 8, 2019, 12 Noon EST Sign up HERE In 2018, the Department of Justice and the Securities and Exchange Commission continued aggressive enforcement of the FCPA. The Justice Department’s FCPA Corporate Enforcement Policy has begun to bear fruit, and the SEC has continued its steady rate of enforcement. Interestingly, the Justice Department increased the number of criminal indictments...
