Category: General

The Importance of a Separate Board Compliance Committee

Watching the compliance industry and advocating for the compliance profession can be frustrating.  Corporate boards and senior management know the importance of committing to a culture of compliance.  To accomplish that task requires focus, determination and commitment. Words are words but actions are tangible.  In the end, corporate boards and senior management have to act and commit to promote the importance of compliance.  As I...

Remote Compliance Learning on Volkov Law TV

While many legal and compliance professionals work from remote locations, Volkov Law TV offers a vast library of recorded webinars that address hot legal and compliance issues. Volkov Law TV offers a library of 119 recorded webinars for a nominal fee — $8 per webinar for monthly access, or $29 for a month’s access to the entire library. You can access the full library HERE....

Comtech Telecomm Settles OFAC Violations for $894,111

Comtech Telecommunications (“Comtech”) and Comtech EF Data Corp. (“EF Data”) agreed to pay OFAC $894,111 for violations of the Sudan Sanctions Program. Comtech and its subsidiary EF Data sell advanced communications systems, software, and services.  The violations arose when these companies indirectly exported warrantied satellite equipment and facilitated services and training to a Sudanese government-owned entity that was prohibited under OFAC’s Sudan sanctions program. The...

Daimler AG and Mercedes Benz Settle with US for $1.5 Billion for Emissions Cheating

The Justice Department, the Environmental Protection Agency and the California Resources Board  announced a joint settlement totaling roughly $1.5 billion with Daimler AG and its US subsidiary Mercedes Benz to resolve violations of the Clean Air Act and California law from the emissions cheating scandal. The EPA and CARB discovered the violations by conducting tests in the wake of the original Volkswagen emissions cheating scandal. ...

DOJ and CFTC Settle Spoofing Case with Scotiabank for $127.4 Million

In the last five years, the Justice Department and the Commodities Futures Trading Commission have aggressively prosecuted “spoofing” cases.  While the government’s record in these cases has been mixed, the government has been successful in securing guilty pleas and winning high-profile trials against traders. Prosecutors have continued to push spoofing prosecutions to root out the conduct.  “Spoofing” refers to traders who engage in bogus conduct...

Deutsche Bank Settles Two OFAC Cases Totaling $583K for Violations of Ukraine-Russia Sanctions

Deutsche Bank continues to have its problems – legal, compliance and reputational.  Now, we can add OFAC sanctions compliance to the list of Deutsche Bank’s troubles. Deutsche Bank settled two separate matters with OFAC – one involving the processing of a large transaction connected to IPP Oil Products (Cyprus) Ltd, a Specially Designated National, and another for 61 transactions involving Open Joint Stock Company Krasnodar...

The Importance of the Internal Audit and Compliance Partnership

In the wake of the International Institute of Auditors recent proclamation of a revised and controversial Three Lines of Defense Model, I thought it would be helpful to underscore the importance of the Internal Audit and Compliance functions to effective internal controls, including ethics and compliance programs.  In most companies, Internal Audit and Compliance work together effectively to leverage each others’ resources and overall efficiency. ...

Herbalife FCPA Settlement is An Important Reminder: Global Companies Need to Focus on Foreign Government Touchpoints

Jessica Sanderson, Partner at the Volkov Law Group rejoins us for a posting on the Herbalife FCPA settlement and lessons learned. Jessica can be reached at jsanderson@volkovlaw.com. As we look past the Herbalife FCPA settlement with DOJ and the SEC for $123 million to resolve FCPA bribery and books and records violations, we are reminded of the variety of foreign government touchpoints and FCPA risks. ...