Category: General

General

12 Mar, 2023

DOJ Announces New Requirements for Compliance Compensation Systems and Business Data Preservation (Part II of II)

The Justice Department promised that it would flesh out compliance program incentives requirements and preservation of business data as part of its revision of its Corporate Enforcement Policy.  In a pair of important speeches, DOJ officials, Deputy Attorney General Lisa Monaco, and Criminal Division Assistant Attorney General Kenneth Polite, previewed the new policies. Shortly after the speeches, the Justice Department released a new version of...

General

9 Mar, 2023

DOJ Outlines Aggressive White Collar Enforcement Measures and New Compliance Expectations (Part I of II)

The Justice Department continues to push on white collar corporate enforcement, and the intersection of national security sanctions and export controls with corporate criminal enforcement.  Last week, Lisa Monaco, DOJ’s Deputy Attorney General, and Kenneth Polite, Assistant Attorney General of DOJ’s Criminal Division, delivered one-two punches in separate speeches at the ABA White Collar Conference in Miami, Florida.  In their speeches, DOJ announced new enforcement...

General

8 Mar, 2023

Lessons Learned from Ericsson’s DPA Breach: An Internal Investigation Nightmare (Part III of III)

This is not your typical FCPA enforcement action Lessons Learned column.  Instead, Ericsson’s breach of its DPA presents a laundry list of internal investigation errors – as a practitioner in this area, this is the nightmare scenario.  It is a cautionary tale for all investigators, whether conducted by internal staff or outside counsel. Before getting into the nitty-gritty of the internal investigation deficiencies, I would...

General

8 Mar, 2023

Ericsson’s DPA Breach Conduct – Failures to Disclose and Report (Part II of III)

Ericsson’s breach of its 2019 Deferred Prosecution Agreement reads like an internal investigation horror show.  It is every investigator’s nightmare scenario – failure to discover evidence that was available to inform and understand the full scope of corporate misconduct.  For Ericsson, these failures have undermined the integrity of its corporate commitment to compliance and ethical culture, damaged even further its reputation and threatened its relationship...

General

6 Mar, 2023

Ericsson Settles Breach of 2019 FCPA Deferred Prosecution Agreement: Agrees to Plead Guilty, Pay $206 Million, and Extend Corporate Monitorship (Part I of III)

Ericsson, a multinational telecommunications company, based in Sweden, settled its breach of its 2019 Deferred Prosecution Agreement, agreed to enter a guilty plea and pay a $206 million penalty.  In 2019, Ericsson entered into a three-year DPA, paid a $1 billion penalty to DOJ and the SEC for FCPA violations.  DOJ notified Ericson in 2021 that it had breached the DPA by violating the DPA’s...

General

2 Mar, 2023

DOJ Rolls Out Voluntary Disclosure Program for US Attorneys’ Offices

The Justice Department is on a marketing campaign – pushing a simple message.  If your company commits misconduct, come in and confess to the Justice Department.  To push this message, DOJ has tinkered with its Corporate Enforcement Policy, and bent over backwards to encourage, cajole and persuade companies to come in and confess to misconduct. The Justice Department consists of various components and, unless you...

General

1 Mar, 2023

United States Announces Sweeping New Sanctions Against Russia

Alex Cotoia, Regulatory Manager at The Volkov Law Group, rejoins us for another important post on new Russian sanctions. Alex can be reached at [email protected]. On February 24, 2023—the first anniversary of the Russian Federation’s Ukraine incursion—the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) and the Department of Commerce’s Bureau of Industry and Security (“BIS”) announced a sweeping new set...

General

28 Feb, 2023

DOJ Flexes Enforcement Muscle to Target Viktor Vekselberg, a Russian Oligarch and Co-Conspirator Assisting in Evasion of Russia Sanctions

I am sticking with my 2023 prediction – DOJ is committed to aggressive enforcement of the Russia sanctions.  Most of its efforts to date have been directed against Russian Oligarchs and significant evaders who are moving products and facilitating financial transactions that directlty or indirectly further Russia’s invasion of the Ukraine. On the one-year anniversary of Russia’s unprovoked invasion of the Ukraine, DOJ announced a...

General

27 Feb, 2023

A Window into Corporate Boards’ Views for 2023

It is fun to follow all the early year views of trends, predictions and survey results.  The beginning of the year includes lots of perspectives and analyses.  Corporate boards are at the center of these important views.  In a recent survey released by National Association of Corporate Directors, the top trends unsurprisingly referred to economic worries – inflation, a potential recession and continuing business disruptions....

General

23 Feb, 2023

The Volkov Law Group is Hiring: Mid-Level Associate

The Volkov Law Group is offering a great opportunity for a mid-level, experienced attorney. The Volkov Law Group is a nationally-recognized boutique law firm that offers a variety of services, including white collar criminal defense, internal investigations , and ethics and compliance services, including anti-corruption, export and sanctions compliance, anti-money laundering, due diligence and third-party risk mitigation. We offer an innovative work environment with virtual offices across...

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