Author: Michael Volkov

General

29 Nov, 2023

Lessons Learned from the Tysers Insurance Brokers and H.W. Wood Limited FCPA Settlements (Part III of III)

The Tysers and Wood FCPA settlements reflect something old and something new in the FCPA enforcement world.  On the old side, at the core of the FCPA violations was the critical role played by the intermediary company.  Unlike most third-party FCPA cases, where a third-party may be enlisted to further a bribery scheme by funneling payments directly to a foreign official, the intermediary in the...

General

28 Nov, 2023

U.K. Reinsurance Bribery Scheme — the Critical Role Played by the Third-Party Intermediary (Part II of III)

As I always say, the factual underpinnings of every FCPA enforcement action provides important insights into bribery schemes.  At the core of every scheme is the misappropriation of money from the company coffers for improper uses.  To the extent a company has weak financial controls and is at risk for internal fraud, such risks may translate into anti-bribery risks depending on its specific corruption profile...

Podcasts

27 Nov, 2023

Episode 299 — Bobby Butler on the Compliance Profession and the Future of Compliance

Bobby Butler, a well-known and long-time compliance professional, joins Michael Volkov for a thought-provoking discussion on the rise of the compliance profession. Bobby has had a long and successful career in compliance. He provides important insights into the evolution of the compliance profession, strategies for building compliance programs and the future of compliance and the compliance profession.

General

20 Nov, 2023

Justice Department Declines FCPA Prosecution Against Lifecore Biomedical Under Corporate Enforcement Policy

The Justice Department has brought three corporate FCPA enforcement actions in 2023 (if you include the Ericsson DPA breach settlement).  With its recent announcement of a declination under the Corporate Enforcement Policy, DOJ has declined two FCPA cases and one healthcare fraud case in 2023. DOJ publicizes the declination letters issued in accordance with the Corporate Enforcement Policy.  DOJ officials have made numerous public statements...

Podcasts

20 Nov, 2023

Episode 298 — Electronics Communications Risks in the Era of Ephemeral Messaging

Companies have a vested interest in preserving internal communications for a variety of reasons — to hold actors accountable, and to protect the organization from potential private and government claims or investigations that may have serious direct or collateral consequences. Companies that want to use ephemeral messaging systems can do so but they have to understand the risks involved and tailor appropriate controls and procedures...

General

16 Nov, 2023

SEC and DOJ Charge SafeMoon Cryptocurrency and its Executives For Multi-Million Dollar Fraud

Matt Stankiewicz, Partner at The Volkov Law Group, provides a post on the latest fraud charges in the cryptocurrency industry, brought against SafeMoon. Matt can be reached at mstankiewicz@volkovlaw.com. On November 1, 2023, the U.S. Department of Justice (“DOJ”) and U.S. Securities and Exchange Commission (“SEC”) brought charges against cryptocurrency project SafeMoon LLC and its U.S. subsidiary SafeMoon US LLC, along with its three executives,...

General

14 Nov, 2023

DOJ’s Latest Opinion Release Underscores Absence of Corrupt Intent and Lack of Business Purpose

The Justice Department has had a slow year in FCPA enforcement (another profound grasp of the obvious).  The reasons for this may be a question of timing elements in the pipeline of cases.  What is clear is that pushing through an enforcement action and settlement requires increased coordination with a growing number of international partners.  That may be part of the explanation. In this environment,...

General

13 Nov, 2023

Gan Integrity and Control Risks Webinar: From Compliance to Sustainability

From Compliance to Sustainability December 6, 2023 10 am EST/4 pm CET SIGN UP HERE Gan Integrity and Control Risks have announced an important upcoming webinar addressing the evolving third-party risk management context — From Compliance to Sustainability. Third-party risk management has evolved at a rapid pace over the past decade. The regulatory environment has quickly followed suit. Enterprises, however, are struggling to keep up...

Podcasts

13 Nov, 2023

Episode 297 — Susan Divers on LRN’s 2023 Program Effectiveness Report

LRN’s annual Program Effectiveness Report is chock full of important findings.  Frankly, LRN’s PEI Report is a “board worthy” report (as Donna Boehme used to say — every board member should read it). Susan and Michael discuss several important findings in LRN’s 2023 Report: High-performing ethics and compliance programs rely principally on values to motivate and guide ethical and compliant behavior — LRN’s Report confirms again...

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General

7 Nov, 2023

Despite OFAC Sanctions Relief, the Venezuelan Oil and Gas Industry Still Presents Risks

Matt Stankiewicz, Partner at The Volkov Law Group PC, provides important context regarding OFAC’s new General Licenses under the Venezuela Sanctions Program. Matt can be reached at mstankiewicz@volkovlaw.com. As we discussed previously, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) recently provided Venezuela with much needed sanctions relief.  Specifically, OFAC issued General License 44 (among others) that broadly authorizes transactions related to...

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