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General

17 Jan, 2025

DOJ’s Balancing Act — Incentives to Cooperate and Deterrence (Part III of III)

While DOJ did not have an overwhelming FCPA enforcement year, DOJ has devoted significant energy to tweaking its enforcement and compliance policies.  These measures were believed to coincide with a number of significant prosecutions — but alas, they really did not materialize.  The modifications and tweaks to DOJ’s Corporate Enforcement Policy, however, were significant.  DOJ’s primary focus has been on accountability and prosecution of individuals...

General

15 Jan, 2025

FCPA 2024 Enforcement — Bribery Schemes and Compliance Reminders (Part II of III)

Criminals can be creative — that is a true statement but essentially FCPA criminals have to embrace a variety of well-established techniques to accomplish a straight-forward goal — steal money from the company to funnel bribery payments to foreign officials.  The complement of 2024 FCPA cases saw some of our standard techniques (or schemes) but a few presented some new twists.  To help organize these...

General

15 Jan, 2025

The FCPA Year in Review — More of the Same with Some Twists (Part I of III)

With the end of the Biden Administration, it is hard to identify a consistent theme relating to FCPA enforcement.  On the one hand, the Biden Administration talked a big game, elevating the anti-corruption fight as a national security priority and promising even more aggressive FCPA enforcement than the prior Trump Administration.  At the same time, the Justice Department modified its Corporate Enforcement Policies, tightening the...

General

13 Jan, 2025

C.H. Robinsom Settles with OFAC for $257,690 to Resolve Iran and Cuba Sanctions Violations

C.H. Robinson International Inc. (CHR), a Minnesota-based global transportation and logistics company, has agreed to pay $257,690 to settle civil liability for 82 apparent violations of sanctions against Iran and Cuba conducted by five of its non-U.S. subsidiaries. Over a period of more than three years, these five subsidiaries provided freight brokerage or transportation services for 82 shipments, to or from Iran, of Iranian- or...

Podcasts

12 Jan, 2025

Episode 351 — Deep Dive in AAR Services FCPA Settlement

How did a high-stakes bribery scheme involving insider deals, Airbus planes, and secret payments bring down a global aviation giant? In this episode, Michael Volkov dives deep into the AAR Corporation FCPA case—a cautionary tale of bribery, insider deals, and compliance failures in high-risk sectors. The DOJ and the Securities and Exchange Commission (SEC) closed 2024 with a major coordinated settlement with AAR Corporation, a...

General

9 Jan, 2025

BIS Reaches $180,000 Mitigated Settlement with Indium Corporation Over Illegal Exports to Russia

The U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) recently issued a Final Order against The Indium Corporation of America, citing eleven (11) alleged violations of the Export Administration Regulations (“EAR”) between April 14, 2022, and March 31, 2023. The violations involved unauthorized exports of solder preforms, solder wires, and solder ribbons to Russia. These items, though classified as EAR99, required an export...

General

9 Jan, 2025

OFAC Closes Out Year with String of Enforcement Actions — Aiotec Pays OFAC $14.55 Million to Resolve Iran Sanctions Violations

Despite a relatively slow year in OFAC sanctions enforcement, OFAC closed 2024 with a string of settlements in five cases, including its second in 2024 against an individual defendant.  While OFAC had a slow year, DOJ continued to increase its criminal enforcement of sanctions cases against individuals, increasing its prosecutions to 70 in 2024, nearly 30 more than 2023 (42). However, in 2024, DOJ did...

General

8 Jan, 2025

AAR’s Bribery Schemes: Bribery in the Aviation Industry (Part II of II)

AAR, a provider of aviation products and services, engaged in two separate bribery schemes.  State-owned entities and government agencies permeate the aviation industry.  As a result, FCPA risks are embedded in direct industry activity and related services and suppliers.  The AAR case is a perfect example of just how easy it is to engage in bribery in the aviation industry. AAR engaged in two separate...

General

7 Jan, 2025

DOJ and SEC Close 2024 with FCPA Enforcement Action Against AAR Corp; DOJ and SEC Announces Resolution with Deepak Sharma, CEO of AAR Subsidiary (Part I of II)

The Justice Department and the SEC  finished 2024 with a coordinated resolution of criminal and civil FCPA charges against AAR Corporation, an Illinois-based provider of aviation products and services.  In addition, DOJ unsealed a criminal indictment and guilty plea dated August 1, 2024, by Deepak Sharma, CEO of an AAR Subsidiary for his role in the FCPA scheme. Also, the SEC entered into a separate civil...

General

6 Jan, 2025

OFAC Designates Gazprombank for Inclusion on SDN List 

By: Daniela Melendez, Associate at The Volkov Law Group, and Alex Cotoia, Regulatory Compliance Manager. Daniela can be reached at [email protected] and Alex can be reached out at [email protected]. In a significant development underscoring the U.S. government’s continued efforts to counter Russia’s destabilizing activities, the U.S. Department of the Treasury recently announced the designation of Gazprombank as a Specially Designated National (“SDN”) under Executive Order 14024. This action,...

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