Alex Cotoia, Regulatory Manager at The Volkov Law Group, recently appeared on David Noah’s podcast to review the Bureau of Industry and Security’s enforcement action against Pratt & Whitney for violation of the Anti-Boycott regulations. You can listen/watch the podcast HERE. Alex Cotoia’s blog post on the enforcement action is HERE.
The Albemarle FCPA enforcement action was announced at a good time. This year has been a slow year for DOJ’s FCPA enforcement program, although there are several months before the end of the year. The SEC, on the other hand, has been steady this year — the Albemarle and Clear Channel enforcement actions are numbers eight and nine for the year. The Albemarle enforcement action...
Albemarle’s bribery schemes look and sound like text-book examples of third-party agents being paid high commissions as a way to funnel bribery payments to foreign officials at state-owned oil refineries. However, as usual, there is more than meets the eye in the factual descriptions. The DOJ and SEC settlements focused on bribery conduct in Vietnam, Indonesia and India. However, the SEC also cited Albemarle’s control...
Albemarle Corporation (Albemarle), a specialty chemicals manufacturing company located in Charlotte, North Carolina, agreed to pay more than $218 million to settle FCPA investigations with DOJ and the SEC stemming from bribery payments in Vietnam, Indonesia and India. Albemarle entered into a three-year non-prosecution agreement (“NPA”) with DOJ and agreed to pay a penalty of approximately $98.2 million and an administrative forfeiture of approximately $98.5...
Sam Finkelstein, Associate at The Volkov Law Group, rejoins us for another post on an OFAC enforcement action. Sam can be reached at [email protected]. Emigrant Bank (“Emigrant”), a U.S.-based financial institution that bills itself as the oldest bank in New York City, is the latest sanctions violator to be swept up in OFAC’s ongoing enforcement push. On September 21, OFAC announced that Emigrant agreed to...
On September 22, 2023, the U.S. Department of Treasury Office of Foreign Assets Control (“OFAC”) issued its “Reminder to file your 2023 annual report of Blocked Property,” noting that entities or persons subject to the reporting requirement must submit a comprehensive report of all blocked property held as of June 30, 2023, by September 30, 2023, which is a Sunday. We are encouraging our clients...
Sam Finkelstein, an Associate at The Volkov Law Group, rejoins us for another posting about 3M’s recent settlement for violations of the Iran Sanctions Program. Sam can be reached at [email protected]. The past few weeks have not been kind to 3M. The company recently settled with the SEC for $6.5 million to resolve alleged FCPA violations related to its Chinese subsidiary’s dealings with Chinese state-owned...
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). LRN’s Report notes that its large data set contains the survey results from 1,860 ethics and compliance professionals from organizations around the world. As explained by LRN, the compliance industry continues to...
Sam Finkelstein, Associate at The Volkov Law Group, rejoins us for a new posting on OFAC’s announcement of new sanctions targeting Russia’s military-industrial complex. Sam can be reached at [email protected]. The United States is determined to ensure that no one profits off of Russia’s war against Ukraine. To that end, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has widened the...
Alex Cotoia, Regulatory Manager at The Volkov Law Group, joined Tom Fox for a Diligent-Sponsored Podcast on building a stronger culture of compliance. You can listen to the Podcast Here. Tom Fox conducted a special series this week on building a stronger culture of compliance through targeted and effective training sponsored by Diligent. This week, Tom visited with Yvette Hollingsworth-Clark, Viktor Culjak, Jessica Czeczuga, Michael...
