Matt Stankiewicz, Partner at The Volkov Law Group, provides an update on the latest OFAC action against CoinList. Matt can be reached at mstankiewicz@volkovlaw.com. 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...

On November 21, 2023, The U.S. Department of Justice (“DOJ”) announced settlement agreements with Binance Holdings Limited (“Binance”), the world’s largest cryptocurrency exchange, and Changpeng Zhao (affectionally known as “CZ” in the cryptocurrency industry), the exchange’s founder and Chief Executive Officer (“CEO”).  Under these agreements, Binance and CZ each agreed to plead guilty to a variety of offenses in order to resolve the ongoing investigations. ...

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 mstankiewicz@volkovlaw.com. 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. ...

Matt Stankiewicz, Partner at The Volkov Law Group, continues his series of posts breaking down Binance’s recent criminal settlement. Matt can be reached at mstankiewicz@volkovlaw.com. Binance’s settlement with the DOJ represents one of the largest criminal corporate enforcement actions ever.  A review of the facts reveals that the penalty is likely warranted, as the misconduct was driven from the very top.  Binance’s founder and CEO,...

Matt Stankiewicz, Partner at The Volkov Law Group, breaks down Binance’s recent criminal settlement agreements with U.S. regulators. Matt can be reached at mstankiewicz@volkovlaw.com. On November 21, 2023, The U.S. Department of Justice (“DOJ”) announced settlement agreements with Binance Holdings Limited (“Binance”), the world’s largest cryptocurrency exchange, and Changpeng Zhao (affectionally known as “CZ” in the cryptocurrency industry), the exchange’s founder and Chief Executive Officer...

FCPA Enforcement and Compliance Review January 9, 2024, 12 Noon EST Sign Up Here Sanctions Enforcement and Compliance Review January 16, 2024, 12 Noon EST Sign Up Here Start the New Year off right — review 2023 FCPA enforcement and compliance on January 9, 2024, and then one week later, on January 16, 2024, review 2023 sanctions enforcement and compliance. FCPA: For the Justice Department...

Steve Naughton, a well-known and accomplished compliance professional, joins Michael Volkov to discuss his compliance career and his role as the Director of Regulatory Compliance Studies and Clinical Professor at the Loyola University Chicago Law School. Steve has served in a variety of important roles in corporate compliance, including Pepsi. Co, and Kimberly-Clark, as well as the Monitor appointed to the Volkswagen case. In this...

As everyone knows, I tend to repeat myself — DOJ does as well.  Over the past year, DOJ has warned global companies — over and over — about the coming criminal enforcement storm against companies for sanctions and export control violations.  Deputy Attorney General Monaco coined the phrase — “the new FCPA,” to reiterate that companies would be prosecuted akin to FCPA enforcement, meaning that...

DOJ announced settlements with two U.K.-based reinsurance brokers, H.W. Wood Limited (“Wood”) and Tysers Insurance Brokers (“Tysers”) for their participation in a bribery scheme involving Seguros Sucre S.A. (“Sucre”) and Seguros Rocafuerte S.A. (“Rocafuerte”), two state-owned insurance companies in Ecuador.  Wood and Tysers each entered into a three-year deferred prosecution agreement with DOJ and agreed to the filing of a criminal information in the Southern...

The Justice Department’s Corporate Enforcement Policies and Program applies to prosecutions outside of the FCPA context.  The impact of DOJ’s new approach, encouraging voluntary disclosures, applies to other federal criminal cases, such as healthcare fraud.  In a recent action, DOJ declined to prosecute HealthSun Health Plans (“HealthSun”) for violations of wire fraud and healthcare fraud. From 2015 until 2020, HealthSun’s former Director of Medicare Risk...