Category: General

General

11 Dec, 2023

DOJ Reaches Groundbreaking Criminal Settlement with Cryptocurrency Exchange Binance and CEO Changpeng Zhao (Part I of III)

Matt Stankiewicz, Partner at The Volkov Law Group, breaks down Binance’s recent criminal settlement agreements with U.S. regulators. Matt can be reached at [email protected]. On November 21, 2023, The U.S. Department of Justice (“DOJ”) announced settlement agreements with Binance Holdings Limited (“Binance”), the world’s largest cryptocurrency exchange, and Changpeng Zhao (affectionally known as “CZ” in the cryptocurrency industry), the exchange’s founder and Chief Executive Officer...

General

7 Dec, 2023

U.S. Government Charges Parties with Violating U.S. Sanctions and Export Control Laws 

By: Alexander J. Cotoia currently serves as the Regulatory Compliance Manager at The Volkov Law Group, where he regularly advises the firm and its clients on the latest developments implicating trade compliance concerns. He may be reached at [email protected]; and Daniela Melendez, Associate at the Volkov Law Group she may be reached at [email protected] As we have repeatedly noted in the context of other blog...

General

7 Dec, 2023

Combatting Corruption: Marking the Anniversary of the Anniversary of the UN Corruption Convention’s Ratification

By: Daniela Melendez Garces, Associate at The Volkov Law Group UN Corruption Convention’s Ratification In October 2003, the General Assembly officially ratified the United Nations Convention against Corruption (“Corruption Convention”). Since that time, a total of 190 countries have ratified the Corruption Convention and agreed to be bound by its anti-corruption obligations. This marks the first time in recent history, where most of the countries...

General

5 Dec, 2023

BIS Ramps Up Antiboycott Enforcement Efforts

Alexander J. Cotoia currently serves as the Regulatory Compliance Manager at The Volkov Law Group, where he regularly advises the firm and its clients on the latest developments implicating trade compliance concerns. He may be reached at [email protected]. On November 3, 2023, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) announced that a settlement had been reached with Forta —a domestic synthetic fiber...

General

4 Dec, 2023

DOJ Repeats Warnings on Aggressive Criminal Enforcement of Sanctions and Export Controls

As everyone knows, I tend to repeat myself — DOJ does as well.  Over the past year, DOJ has warned global companies — over and over — about the coming criminal enforcement storm against companies for sanctions and export control violations.  Deputy Attorney General Monaco coined the phrase — “the new FCPA,” to reiterate that companies would be prosecuted akin to FCPA enforcement, meaning that...

General

1 Dec, 2023

DOJ Declines Prosecution Applying Corporate Enforcement Program in Healthcare Fraud Case

The Justice Department’s Corporate Enforcement Policies and Program applies to prosecutions outside of the FCPA context.  The impact of DOJ’s new approach, encouraging voluntary disclosures, applies to other federal criminal cases, such as healthcare fraud.  In a recent action, DOJ declined to prosecute HealthSun Health Plans (“HealthSun”) for violations of wire fraud and healthcare fraud. From 2015 until 2020, HealthSun’s former Director of Medicare Risk...

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...

General

28 Nov, 2023

Two UK Reinsurance Brokers Settle with DOJ for FCPA Violations in Ecuador (Part I of III)

By MICHAEL VOLKOV, NOVEMBER 27, 2023 DOJ announced two recent FCPA settlements with U.K. based reinsurance brokers involving a long-running bribery scheme involving two Ecuadoran state-owned insurance companies.  While DOJ has had a slow year in FCPA enforcement, DOJ is probably likely to announce additional FCPA settlements by the close of the year.  In its most recent announcement, DOJ announced settlements with two U.K.-based reinsurance...

General

22 Nov, 2023

BIS and FinCEN Release Joint Notice Concerning Global Export Control Evasion 

Alexander J. Cotoia currently serves as the Regulatory Compliance Manager at The Volkov Law Group, where he regularly advises the firm and its clients on the latest developments implicating trade compliance concerns. He may be reached at [email protected]. On November 6, 2023, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) and the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) released...

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