The Treasury Department’s Office of Foreign Asset Control (“OFAC”) announced its third enforcement action for 2018. While OFAC has been busy with implementing new sanctions regimes and re-imposing the Iran sanctions regime, OFAC is beginning to clear some of the enforcement matters that have been pending. JP Morgan Chase agreed to a $5.2 million settlement with OFAC for 87 apparent violations from the processing of...
Karin Sweigart rejoins us for another interesting posting on employment compliance issues. Karin can be contacted at ksweigart@volkovlaw.com. It is estimated about half of the United States’ 1.5 million internships a year are unpaid, a number that may go up due to changes in the Department of Labor’s (DOL) rules governing unpaid internships. Implemented in 2018, the updated rules provide for-profit companies more flexibility to...
Compliance officers have a difficult job. So why are so many people interested in joining the profession? At bottom, compliance professionals are inspirational professionals and inspired by their mission. Compliance officers have a mission – to embed and promote a culture of ethics and compliance. When you boil it down, every compliance officer is dedicated to two specific missions: to embed and protect its culture,...
I have a tendency to sound like a “broken record” (an odd phrase in these days of digital music). The government’s most powerful enforcement tool continues to be – drumroll please, the False Claims Act. The government “always” (or in most cases) wins. Defendants are rarely willing to risk exclusion from valuable federal healthcare programs or defense contracts. When the government brings a case, the...
Karin Sweigart, a Senior Associate at The Volkov Law Group, rejoins us for a posting on employees and political activity. Karin can be reached at ksweigart@volkovlaw.com. It is October in an election year, and political tensions are running high. If political discourse in your place of business has been heated, it may be a good time for a refresher on laws governing what private employers...
The Treasury Department’s Office of Foreign Asset Control (“OFAC”) announced its third enforcement action for 2018. While OFAC has been busy with implementing new sanctions regimes and re-imposing the Iran sanctions regime, OFAC is beginning to clear some of the enforcement matters that have been pending. JP Morgan Chase agreed to a $5.2 million settlement with OFAC for 87 apparent violations from the processing of...
Karin Sweigart rejoins us for another interesting posting on employment compliance issues. Karin can be contacted at ksweigart@volkovlaw.com. It is estimated about half of the United States’ 1.5 million internships a year are unpaid, a number that may go up due to changes in the Department of Labor’s (DOL) rules governing unpaid internships. Implemented in 2018, the updated rules provide for-profit companies more flexibility to...
Compliance officers have a difficult job. So why are so many people interested in joining the profession? At bottom, compliance professionals are inspirational professionals and inspired by their mission. Compliance officers have a mission – to embed and promote a culture of ethics and compliance. When you boil it down, every compliance officer is dedicated to two specific missions: to embed and protect its culture,...
I have a tendency to sound like a “broken record” (an odd phrase in these days of digital music). The government’s most powerful enforcement tool continues to be – drumroll please, the False Claims Act. The government “always” (or in most cases) wins. Defendants are rarely willing to risk exclusion from valuable federal healthcare programs or defense contracts. When the government brings a case, the...
Karin Sweigart, a Senior Associate at The Volkov Law Group, rejoins us for a posting on employees and political activity. Karin can be reached at ksweigart@volkovlaw.com. It is October in an election year, and political tensions are running high. If political discourse in your place of business has been heated, it may be a good time for a refresher on laws governing what private employers...
United Technologies recently settled an FCPA enforcement action with the SEC by paying $13.9 million for bribes paid by its elevator and aircraft businesses. UT disclosed the investigation to DOJ and the SEC in late 2013 or early 2014. DOJ declined to prosecute in March 2018. UT agreed to disgorge $9 million, plus interest of about $919,000 and to pay a penalty of $4 million. The SEC’s FCPA settlement contains...
Webinar: The State of Third-Party Risk Management in 2018 Date: Tuesday, October 16 Time: 1:00 PM/ET/10:00 AM PT Duration: 60 minutes Sign Up HERE Over half of organizations leave themselves open to risk with an ineffective or non-existent third-party risk management program. That’s shocking given the damage a third party can inflict! To improve or get started on your third-party risk management program, join this...
Believe it or not, but companies are still struggling with third-party risk management systems. I know this sounds hyper-critical but many companies continue to hang onto paper due diligence systems (sometimes with or without a SharePoint platform to store third-party due diligence documentation). An even smaller percentage of companies are automating their due diligence programs, a basic requirement for all companies with a minimum number...
Webinar: Advanced Ethics and Compliance Program November 6, 2018, 12 Noon EST Sign Up HERE As companies’ ethics and compliance programs mature, chief compliance officers face new challenges to evolve their compliance programs. CCOs have to make important decisions on how to address the company’s culture, commitment to organization justice, changing risk profiles and global performance. Join Michael Volkov, CEO of The Volkov Law Group,...
The United Technologies FCPA settlement underscored, once again, the harm to a company when lawyers fail to do their job. As outlined in the SEC settlement, an in-house attorney at Otis Elevator was required to review and approve a contract with a third-party, where a cursory due diligence review would have uncovered major red flags. The in-house attorney reviewed the contract without inquiring about the...
