Happy Thanksgiving!
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Category: General
The Continuing Importance of Conflict of Interest Compliance
We continue to hear about the impact of apparent or real conflicts of interest — whether in government, in business, or in other organizations. It is an issue of significant importance. Within an organization, a perceived or real conflict of interest can undermine the very integrity of the organization and a specific person’s ability to act in a manner consistent with the organization’s interests. Scandals...
Measuring Compliance Program Performance and Effectiveness
“Only when the tide goes out do you discover who’s been swimming naked.” — Warren Buffett You often hear chief compliance officers speak about benchmarking. CCOs often reveal their competitive streaks when they collect information about other companies’ compliance programs. It can easily come off as a little insecure. In fact, CCOs are seeking valuable information — trying to measure their company’s performance outside their...
Lessons Learned from the Telefónica FCPA Settlement (Part III of III)
The Justice Department’s record of FCPA enforcement in 2024 has been disappointing. With all of the hoopla and pronouncements surrounding the global war against corruption, DOJ suggested that enforcement in 2023 and 2024 would be robust. Instead, 2024 was a year of fizzles, fits and starts, and ultimately a slow year of FCPA enforcement. The future under the Trump Administration will be interesting. Based on...
Telefónica’s Bribery Scheme — The Usual Suspects and Tools (Part II of III)
We should all admit something (among many things) — reading through factual statements of bribery offenses, the facts all start to meld together. Criminals are not as ingenuous or creative as they think, and the schemes they employ are fairly straightforward. Let’s start with one profound grasp of the obvious — To pay bribes, criminals have to “steal” money from the company, that is, they...
Telefónica Pays $85.2 Million to Settle FCPA Charges involving Venezuela Bribery (Part I of III)
Telefónica Venezolana C.A. (“Telefónica Venezolana”), the Venezuela-based subsidiary of Telefónica S.A. (Telefónica), the Spanish telecommunications company entered into a deferred prosecution agreement (“DPA”) and agreed to pay over $85.2 million to resolve DOJ FCPA charges stemming from bribery payments to Venezuelan government officials to secure preferential access to U.S. dollars in a currency auction. Telefónica Venezolana entered into a three-year DPA and the filing of a...
The Trump Administration’s Focus on the Department of Justice and Priorities (Part III of III)
The Justice Department is about to undergo some fundamental changes. The 2nd Trump Administration will take some initial broad strokes designed to increase accountability and control of prosecutors and laws enforcement. The FBI The first on the chopping block is the FBI. Under existing law, the FBI is a component of the U.S. Department of Justice, presumably under the control and oversight of the Attorney...
Forecasting the 2nd Trump Administration: Foreign Policy Changes and Increased Trade and Tariff Enforcement (Part II of III)
The 2nd Trump Administration will mean significant change in foreign policy, most especially the importance of ending the Russia-Ukraine war, increased focus on Iran and its proxies, and aggressive use of trade policies and tools to execute the policy and promote United States businesses. Since the start of the Russia-Ukraine war and the unprecedented global sanctions and export controls regime, trade enforcement and compliance have...
Forecasting the 2nd Trump Administration: Translating Initiatives to Enforcement and Compliance Priorities (Part I of III)
As the dust settles on the U.S. Election, companies are quickly analyzing the impact for businesses, federal civil and criminal enforcement priorities and the implications for ethics and compliance. When a new Administration comes into power, change is inevitable and can be far-reaching. Given the change with President Trump’s return to the White House, and in light of several of his stated intentions, companies should...
OFAC Imposes $860,000 Penalty on Vietnamese Beverage Company for Violations of North Korean Sanctions
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]. North Korea Sanctions Violations In a recent enforcement action, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) imposed an $860,000 penalty on Vietnam Beverage Company Limited (“VBCL”), a holding company based in Vietnam, for apparent...
