Category: General

DOJ Issues New and More Robust Guidance on Evaluation of Corporate Compliance Programs (Part I of V)

The Volkov Law Group has scheduled a free webinar on DOJ’s New Compliance Program Guidance for May 9, 2019, at 12 noon EST. Sign up HERE. In a major development in ethics and compliance program expectations, the Justice Department has issued a new and important revised guidance on the Evaluation of Corporate Compliance Programs (HERE).  The new Evaluation Guidance supersedes the prior document issued in...

OFAC Enforcement Action Underscores Russia Sectoral Sanctions

The Treasury Department’s Office of Foreign Asset Control (OFAC”) continues its enforcement run.  In a recent case against Haverly Systems, Inc., OFAC sent an important reminder to US companies about compliance with the Ukraine-Russia Sectoral Sanctions Program.  Haverly paid roughly $75,000 for two violations of the Ukraine-Russia Sectoral Sanctions (SSI).  In two transactions, Haverly violated Directive 2 of the Ukraine-Russia the 90-day maturation limitation on...

The Important Link Between Anti-Corruption Compliance and Effective Training Programs

Julie DiMauro, Regulatory Intelligence Expert, Thomson Reuters, and Michael Volkov, CEO, The Volkov Law Group We were honored to jointly present a Thomson Reuters-sponsored webinar focused on Top Anti-Corruption Compliance Risks recently; if you missed it, please find the replay here.  Global anti-corruption risks are increasing at the same time that global cooperation among prosecutors and law enforcement agencies are facilitating the detection and penalization...

DOJ and OFAC Announce Another Sanctions Settlement – UniCredit Group Banks Pay Over $1.3 Billion and Subsidiary Bank Agrees to Plead Guilty for Violating Iran Sanctions

The Justice Department and the Treasury Department’s Office of Foreign Asset Control (OFAC) are on a roll.  Global banks are facing renewed prosecutions, along with aggressive sanctions prosecutions of companies for integrating acquisitions and supply chain missteps. In the latest billion-dollar plus settlement, UniCredit Bank S.p.A UC Group), based in Milan, Italy and two subsidiaries, UniCredit Bank AG (UCB AG), a German bank (aka HypoVereinsbank),...

Acteon Pays $441,000 to Settle Two OFAC Enforcement Actions

We can add Acteon to the list of OFAC settlements for 2019, which is quickly turning into a robust sanctions’ enforcement year.  Acteon is a UK based company, which provides subsea services in the oil and gas industry.  (Acteon recently announced the acquisition of Benthic, an Australian owned subsea company, which operates out of Houston, Texas). In the first enforcement action, Acteon and its operating...

The Long Arm of OFAC: Secondary Sanctions, Facilitation, and Causing a Violation

Matt Stankiewicz, Senior Associate at The Volkov Law Group, rejoins us for a blog posting on OFAC sanctions law. Matt can be contacted at mstankiewicz@volkovlaw.com. Sanctions law can be complex.  The sanctions programs themselves are often a tangled web of do’s and don’t’s – various wind down periods, General Licenses, payment structures, and more.  In order to enforce these laws and regulations, OFAC must necessarily...

NAVEX Global’s 2019 Hotline Benchmark Report

NAVEX Global’s Hotline benchmark report (here) is an excellent annual report which helps companies to understand how well their hotline and incident management system is operating.  The survey is based on over 1 million reports from 2,738 customers.The NAVEX report also is based on all types of reporting avenues, including hotlines and web-based systems. Interestingly, NAVEX noted that overall reporting rates remained consistent with 2016...

OFAC Sanctions Compliance Insights from Standard Chartered Bank Enforcement Action (Part III of III)

The Treasury Department’s Office of Foreign Asset Control (OFAC) has promised to issue guidance on effective sanctions compliance programs.  This is a long-anticipated update to prior information OFAC has released on the same subject. OFAC has raised the stakes for sanctions enforcement, especially with respect to Iran and Venezuela sanctions programs.  So far this year, OFAC has announced a number of significant enforcement actions and...

Standard Chartered Bank’s Continuing Culture Challenges and Sanctions Compliance (Part II of III)

Standard Chartered Bank certainly has its troubles.  You know a company is in trouble, however, when it breathes a sigh of relief after paying nearly $1.1 billion in fines and penalties and compares itself to BNP Paribas, the global French bank, which paid over $8 billion for pervasive US sanctions violations.  The Justice Department and OFAC have had a target-rich environment when reviewing global bank...

Stephen Cheng and Noah Smith Write on Senator Warren’s Corporate Executive Accountability Proposal

Stephen Cheng and Noah Smith, Associates at The Volkov Law Group, recently published an article on Law 360, How Warren Bill Would Change Liability For Corporate Execs. “If the criminal penalties in the Corporate Executive Accountability Act — recently proposed by Sen. Elizabeth Warren, D-Mass. — ever became law, they would usher in sweeping implications for the way big companies approach their legal compliance efforts.”...