May is going to be a rough month for compliance officers — on May 11, 2018, FinCEN’s new Customer Due Diligence(“CDD”) Rule for beneficial ownership becomes effective.  The CDD rule will have a significant impact on the collection of information from customers and AML enforcement.  See here for FinCEN guidance. Many have welcomed these rules as a step in the right direction in combating a significant problem – the ease...

The Volkov Law Group is offering a great opportunity for a senior, experienced attorney and a junior, associate attorney. The Volkov Law Group is a nationally-recognized boutique law firm that offers a variety of services, including criminal defense, securities compliance and defense, and ethics and compliance services, including anti-corruption, export and sanctions compliance, anti-money laundering, due diligence and internal investigations. As a leader in anti-corruption...

As the nattering nabobs of negativism continued to claim that FCPA enforcement was on the decline, the Justice Department and the SEC settled a major FCPA enforcement action with Panasonic Avionics (PAC), a subsidiary of Panasonic which provides in-flight entertainment systems (“IFEs”) to airlines. Panasonic Avionics agreed to pay a criminal fine of $137 million and $143 million in disgorgement.  As part of the settlement,...

We always hear about the dearth of law surrounding the FCPA.  As the Justice Department brings more cases against individuals who are likely to challenge the government’s theories of prosecution, we will see more caselaw develop. In this situation, FCPA and compliance practitioners, as well as in-house and law firm attorneys can obtain the definitive guide to FCPA law, including caselaw, DOJ and SEC enforcement...

The FLIR Systems settlement is an extraordinary event given the sheer number of violations, the systemic breakdown that occurred, and the absence of any meaningful compliance controls.  It is all the more surprising given the fact that FLIR’s operations are devoted in large proportion to the highly-regulated international defense industry market.  Given the level of risk, you would expect FLIR to have in place systems...

In an extraordinary enforcement action, the US Department of State reached a comprehensive settlement with FLIR Systems, Inc. (FLIR) to resolve violations of the Arms Export Control Act and the International Traffic in Arms Regulations (ITAR).  These acts are administered by the Office of Defense Trade Controls Compliance in the Department’s Bureau of Political-Military Affairs (DTCC). Under the settlement, FLIR will pay a civil penalty...

The Volkov Law Group has joined forces with NAVEX Global’s innovative compliance website, Compliance Next. The Volkov Law Group is contributing videos and written materials as a proud member of the Compliance Next network. Our first video on internal investigations is HERE. Compliance Next is the first community-driven compliance network, which provides tools and resources to support compliance initiatives and promote successful strategies.  Members of...

Matt Stankiewicz, Associate at The Volkov Law Group, rejoins us for another posting on cryptocurrency regulation.  Matt can be reached at [email protected]. Recently, New York Attorney General Eric T. Schneiderman launched the state’s Virtual Markets Integrity Initiative in order to garner more information and gain insight into the inner workings of cryptocurrency exchanges. To kick off the initiative, the AG’s office sent a questionnaire containing...