Category: General

OFAC & State Department Announce New Russia Sanctions, Targeting Military-Industrial Complex

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...

Diligent Podcast: Alex Cotoia and Tom Fox Discuss Corporate Culture Issues

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...

Do We Really Need an ISO Standard for Internal Investigations?

Call me a skeptic.  Call me cynical. I understand that the International Organization for Standardization (ISO) provides valuable standardization services and guidance.  The ISO is comprised of 169 member countries. The ISO recently issued a new standard governing internal investigations.  From my vantage point, I was a critic of ISO 37001, anti-corruption compliance,  because of its over-generalization and failure to provide more specific guidance on...

A Compliance Reminder: Focus on Your Culture

We all agree on the importance of corporate culture.  Everyone gets it – corporate leaders mouth the words but rarely understand the nuances, and the need to attend to a company’s culture.  Compliance professionals want to devote more time to corporate culture but often are overburdened with less important tasks.  It is easy for compliance professionals to get lost  in the details, theory, and technology...

Catching Up with California and State Data Privacy Laws

The United States continues to suffer from the absence of a federal data privacy and breach law.  Congress has tried for years to broker a deal here but has never been able to overcome strong lobbying forces — whether its high-tech, trial lawyers, law enforcement or other gadflies, the public continues to suffer. Instead, global businesses face a real mess, tracking data privacy laws state-by-state,...

DOJ’s National Security Division Places Corporate Crime in the Crosshairs

Sam Finkelstein, an associate at The Volkov Law Group, rejoins us for a posting on DOJ’s initiative to increase corporate prosecution of sanctions, export controls and national security issues. Sam can be reached at [email protected]. The marriage of corporate enforcement and national security has been a defining feature of the DOJ under the Biden Administration. The Justice Department’s commitment to prosecuting corporate crimes that implicate...

BIS Signals New Enforcement Initiative for Antiboycott Compliance — Pratt and Whitney Settles Antiboycott Violations

Alex Cotoia, Regulatory Compliance Manager at The Volkov Law Group, rejoins us for an interesting posting on BIS’ recent enforcement action against Pratt & Whitney for violation of the antiboycott regulations.  Alex can be reached at [email protected]. On September 27, 2023, the United States Department of Commerce’s Office of Antiboycott Compliance, a division of the Bureau of Industry and Security (“BIS”), publicized an unanticipated and...

DOJ Resolves First Corporate Sanctions Case Involving Iran Sanctions Program

Daniela Melendez, a new Associate at The Volkov Law Group, rejoins us for another blog post on DOJ’s first corporate prosecution for violations of the Iran Sanctions Program.  Daniela can be reached at [email protected]. The Justice Department has touted the upcoming wave of corporate prosecutions for criminal sanctions violation as the era of “The New FCPA.” DOJ’s reference is intended to communicate a strong message...

ECI’s New Survey – The State of Ethics & Compliance in the Workplace

Daniela Melendez, a new Associate at The Volkov Law Group, joins us for her first blog posting.  If you want to contact Daneila, she can be reached at [email protected]. The Ethics and Compliance Initiative (“ECI”) is a terrific organization that provides important ethics and compliance insights and leadership.  Starting in 1994, ECI has conducted a longitudinal, cross-section study of workplace conduct.  ECI recently issued its...