Category: General

General

18 Oct, 2023

Electronic Communications Risks — DOJ Enters the Fray in March 2023 (Part II of III)

Just to play devil’s advocate (or perhaps to push my agenda), I have conflicting views on corporate use of ephemeral messaging applications.  On the one hand, I understand the importance of managing electronics communications data, prioritizing the preservation of relevant data, and reducing attendant costs from managing ever-growing amounts of electronic data.  On the other hand, as a former prosecutor and now defense counsel, I...

General

17 Oct, 2023

Electronic Communications Risks — Asking the Critical Questions? (Part I of III)

Honestly, I have been avoiding this topic since it presents a real morass of risks and potential traps for the unwary company and Chief Compliance and Chief Legal Officers.  When I first examined the issue, I understood DOJ’s frustration.  If bad actors can escape detection and subsequent punishment (internal or external) by using ephemeral messaging applications to delete illegal or improper communications, companies should simply...

General

13 Oct, 2023

OFAC Ramps Up Price Cap Enforcement as Coalition Publishes Compliance Advisory for Maritime Oil Industry

Sam Finkelstein rejoins us for a posting on OFAC’s recent enforcement steps and guidance on Russian Oil Sanctions and the Maritime Industry. Sam can be reached at [email protected]. It looks like the days of Russia’s so-called “shadow fleet” are numbered. The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced Thursday that it had imposed sanctions on two entities, and identified as...

General

12 Oct, 2023

Google’s Failure to Preserve Electronic Communications — A Warning to Every Company of a New Reality Surrounding Electronic Data

Alex Cotoia, Regulatory Manager, and Daniela Melendez, an Associate at The Volkov Law Group, rejoin us for a joint posting reminding readers on the importance of addressing electronic communications preservation and management in this new age of rapid technological change.  Alex can be reached at [email protected], and Daniela can be reached at [email protected].  One thing you can count on — change.  Not that there is...

black android smartphone

General

11 Oct, 2023

Pain in the App: Messaging Apps Lead to Large SEC Enforcement Actions

On September 29, 2023, the U.S. Securities and Exchange Commission charged several firms with recordkeeping failures. These recordkeeping failures relate to pervasive and longstanding off-channel communications.  Generally, all of these actions relate to the widespread use of various messaging apps that ultimately violate SEC requirements and circumvent internal corporate controls.  These are the latest enforcement actions in a string of similar penalties by the SEC...

General

10 Oct, 2023

DOJ Extends Voluntary Disclosure Benefits to Merger and Acquisitions

As part of its continuing effort to encourage corporate voluntary disclosures, the Department of Justice announced revised voluntary disclosure policies applicable to mergers and acquisitions.  In a speech at the recent annual Society of Corporate Compliance and Ethics annual meeting in Chicago, Lisa Monaco, Deputy Attorney General,  outlined the new voluntary disclosure policies. DAG Monaco described the importance of DOJ’s policy promoting corporate commitment to...

General

8 Oct, 2023

Compliance Week Sessions with Volkov Law – November 6th and 7th

Don’t miss our sessions! Volkov Law’s Michael Volkov, Steve Naughton, and Jessica Sanderson will be speaking at Compliance Week’s virtual “Third-Party Risk Management Oversight Summit” on November 6 and 7, 2023. Compliance Week is offering our followers a 15% discount (see code below). Mike and Steve will present together on Monday, November 6th, in an afternoon session entitled, “The ABCs of an Effective Third-Party Risk...

General

5 Oct, 2023

Clear Channel Settles SEC FCPA Case Against Former Chinese Subsidiary for $26.1 Million

The Securities and Exchange Commission continues to rack up FCPA enforcement actions.  In its latest settlement, Clear Channel Outdoor Holdings agreed to pay $26.1 million for bribery violations committed by its former Chinese subsidiary.  According to Clear Channel, the Department of Justice closed its FCPA investigation.  Clear Channel, a San Antonio-based advertising company, paid bribes to Chinese government officials with cash, gift cards, first-class travel,...

Follow:

Michael Volkov
JD Supra Readers Choice Top Author 2024America's Top 100 Criminal Defense Attorneys 2023® Recipient Award Volkov Law Group Click Here

Watch The Latest Webinars on Volkov Law TV

watch-video-button

Listen to the Corruption, Crime & Compliance Podcast

SUBSCRIBE TO CORRUPTION, CRIME & COMPLIANCE



More

Making Money Is Not a Mission

Moving the Goalposts

The Road Ahead

A Return to Common Sense

Pointing the Finger

Pointing the Finger