Category: General

4 Jan, 2023

Digging into Honeywell UOP’s Bribery Schemes in Brazil and Algeria (Part II of III)

The facts surrounding Honeywell’s bribery schemes in Brazil and Algeria are fairly straightforward. In Brazil, the facts underscore the significant risks of bribery when companies participate in large, valuable project competitions. Global companies face significant risks when competing and seek every advantage to win a project competition. Brazil In 2008 and 2009, Petrobras developed the Premium Refinery project to design and construct two grassroots refineries...

General

4 Jan, 2023

DOJ and SEC Close Year with FCPA Settlement with Honeywell UOP for $160 Million (Part I of III)

The Justice Department and the Securities and Exchange Commission had a strong FCPA enforcement year. However, there is certainly more to come and it is easy to predict that 2023 will be even a bigger year. It is fairly obvious that DOJ and the SEC have cases in the pipeline and with new policies in place, they are getting ready to move them through the...

General

3 Jan, 2023

A New Year’s Resolution for Companies involved in Defense Business

Jessica Sanderson, a Partner at The Volkov Law Group, rejoins us for an important posting on the importance of compliance with defense trade controls. Jessica can be reached at [email protected]. On December 5, 2022, the Department of State, Directorate of Defense Trade Controls (“DDTC”) issued new Compliance Program Guidelines, “intended to provide an overview of an effective compliance program and an introduction to defense trade...

General

23 Dec, 2022

From All of Us — Have a Wonderful Holiday and a Happy New Year

From all of us at the Volkov Law Group, we wanted to wish our clients, families, friends, and colleagues a wonderful holiday season and a terrific New Year!! We are so grateful for opportunities to work together, collaborate, and learn from each other. We hope that everyone is able to enjoy some time with their families, loved ones and friends during the holidays. We will...

General

22 Dec, 2022

Bankruptcy Proceedings Reveal Shocking Lack of Controls at Disgraced Cryptocurrency Exchange FTX (IV of IV)

Matt Stankiewicz, Partner at The Volkov Law Group, wraps up his blog series on FTX, highlighting some of the more interesting facts from the company’s recent bankruptcy filing. He can be reached at [email protected]. On top of all the legal trouble for FTX’s founder and CEO, Sam Bankman-Fried (“SBF”), the company has also filed for bankruptcy and SBF has been ousted as CEO. John J. Ray...

General

20 Dec, 2022

The SEC and CFTC Bring Civil Charges against FTX, Alameda, and SBF (III of IV)

Matt Stankiewicz, Partner at The Volkov Law Group, continues his blog series on FTX, discussing the civil charges filed by the SEC and the CFTC. He can be reached at [email protected]. In conjunction with the DOJ’s criminal indictment, the SEC brought civil charges against SBF. The SEC charged SBF with orchestrating a scheme to defraud equity investors in the FTX exchange (FTX Trading Ltd.). The SEC...

General

19 Dec, 2022

The Department of Justice Charges FTX CEO Sam Bankman-Fried in the Southern District of New York (II of IV)

Matt Stankiewicz, Partner at The Volkov Law Group, continues blog series on the collapse of FTX, looking at the criminal charges filed against founder and CEO Sam Bankman-Fried. He can be reached at [email protected]. Following FTX’s stunning collapse, federal prosecutors have quickly taken steps to hold FTX’s founder and CEO Sam Bankman-Fried (“SBF”) accountable. On December 13, the Department of Justice (“DOJ”) announced a criminal...

General

18 Dec, 2022

The Fall of FTX: The Legal Ramifications of the Collapse of Sam Bankman-Fried’s Cryptocurrency Empire (I of IV)

Matt Stankiewicz, Partner at The Volkov Law Group, joins us with a comprehensive blog series that will breakdown the various legal issues facing the fallen cryptocurrency exchange FTX and its disgraced founder Sam Bankman-Fried. He can be reached at [email protected]. The cryptocurrency world is in shock watching the events unfold around the stunning collapse of FTX, one of the largest crypto exchanges in the world. The...

General

15 Dec, 2022

OFAC Due Diligence and Attestation Requirements (Part IV of IV)

OFAC’s guidance is intended to ease the burden on an otherwise difficult compliance problem. Companies have to act in good faith to avoid transacting business involving Russian crude oil that has been sold above the $60 per barrel price cap. For some industry players, compliance is straightforward. However, for a number of players who do not normally have access to specific pricing information, due diligence...

General

14 Dec, 2022

Finding Safe Harbors Under OFAC’s Price Cap Regulations (Part III of IV)

The Biden Administration recognizes that the Russian Price-Cap Policy imposes serious burdens on U.S. energy companies and industries that provide ancillary services to the energy sector. It is even more complicated given the EU framework and another set of guidance related to the oil price cap. To ameliorate this burden, OFAC has set out detailed guidance on regulatory “safe harbors” for organizations and individuals affected...