Category: General

General

6 Nov, 2022

NAVEX 2022 Risk and Compliance Benchmark Report: Ethics and Compliance Program Shortfalls Continue

NAVEX continues to be one of the premier sources of essential annual benchmarking studies.  Recently, NAVEX issued its 2022 Definitive Risk and Compliance Benchmark Report.  The Report was based on over 1100 survey responses from compliance professionals around the world. From the topline view, NAVEX reported that organizations have successfully addressed post-COVID work environments with a combination of on-site, remote and hybrid arrangements.  In this...

General

3 Nov, 2022

Board Director Accountability

We constantly hear about the importance of “accountability,” meaning that organizations and individuals have to be held accountable for misconduct or failures to act.  The focus on accountability is a positive trend, consistent with our ideas of justice and fairness,  Within an organization, accountability is a cornerstone of organizational justice. When demands for accountability reach the board room and individual board members, however, there are...

General

1 Nov, 2022

Navigating DOJ and OFAC Voluntary Disclosures for Sanctions Violations

The Department of Justice is pushing its commitment to voluntary disclosure programs.  Companies, however, are not lining up at DOJ’s door.  The balance between sitting tight or voluntary disclosures requires care. To complicate matters further, in certain cases, regulated companies have to face civil enforcement issues and coordinate voluntary disclosure programs offered by regulatory agencies.   A perfect example of this dual track situation is compliance...

General

31 Oct, 2022

Voluntary Self-Disclosure — DOJ’s Enforcement Engine

The Department of Justice and many regulatory agencies have rolled out the red carpet for companies to cross the threshold and voluntarily disclose criminal conduct in the hopes of gaining leniency, immunity and reduced fines and penalties.  From DOJ’s perspective, a voluntary disclosure program increases DOJ’s ability to prosecute more organizations and individuals engaged in wrongdoing.  Whether DOJ’s voluntary disclosure efforts have been as successful...

General

30 Oct, 2022

DOJ Charges Two Companies and A Dozen Individuals for Export Control and Sanctions Violations to Aid Russian Military

The Justice Department promised aggressive enforcement of export controls and sanctions against Russia.  To that end, DOJ initiated the KleptoCapture task force to focus law enforcement investigations of export violators.  DOJ and the KleptoCapture task force have delivered.  The first significant case confirms the importance of tracking DOJ and law enforcement resources.  When an initiative is announced and includes assignment of personnel, you can rest...

General

27 Oct, 2022

Antitrust Division Keeps on Pushing and Announces Initial Settlements of Potentially Illegal Interlocking Directorates

The Antitrust Division announced last year that it intended to reinvigorate enforcement of Section 8 of the Clayton Act, which prohibits directors and officers serving simultaneously on the boards of competitors (with limited exceptions). Assistant Attorney General Jonathan Kanter continues to implement his aggressive agenda unfazed by his mixed record of success in litigation. In particular, the Antitrust Division has an uneven record in its...

General

26 Oct, 2022

Lafarge and Syrian Subsidiary Pay $778 Million in Fines and Forfeiture for Supporting ISIS Terrorist Organization

The Justice Department continues to push an aggressive agenda against businesses.  It is committed to demonstrating its resolve to prosecute companies and individuals from the business community.  Whether it is antitrust, FCPA, False Claims Act, or other assorted white collar crimes, DOJ continues to demonstrate its focus on white collar crimes.  The lowest-hanging fruit to demonstrate this renewed focus is to focus on companies connected...

General

23 Oct, 2022

OFAC Issues Notice of Violation Against Puerto Rico Bank But Imposes No Penalty for Sanctions Violations

The Department of Treasury’s Office of Foreign Assets Control (“OFAC”) issued a finding of violation (“FoV”) to Nodus International Bank, Inc. (“Nodus”), located in Puerto Rico, for violation of Venezuelan Sanctions. Nordus voluntarily disclosed three unauthorized transactions in which a Specially Designated National (“SDN”) had an interest. Nodus failed to maintain accurate records related to the handling of blocked property.  OFAC determined that a FoV...

silver round coin on green surface

General

20 Oct, 2022

Bittrex’s Sanctions and AML Violations: The Importance of Compliance Controls for the Cryptocurrency Industry (Part II of II)

Matt Stankiewicz, Partner at The Volkov Law Group, continues his discussion of recent enforcement actions by OFAC and FinCEN.  He can be reached at [email protected]. In parallel with the Office of Foreign Assets Control (“OFAC”), the Financial Crimes Enforcement Network (“FinCEN”) settled with Bittrex, Inc. (“Bittrex”), a cryptocurrency exchange that allows users to trader virtual assets, for willful violations of the Bank Secrecy Act (“BSA”)’s...

graph of the movement of the value of bitcoin

General

19 Oct, 2022

OFAC and FinCEN Reach Settlement Agreement with Virtual Currency Exchange Bittrex (Part I of II)

Matt Stankiewicz, Partner at The Volkov Law Group, joins us for a posting on sanctions compliance in the cryptocurrency industry.  He can be reached at [email protected]. On October 11, 2022, the Office of Foreign Assets Control (“OFAC”) and the Financial Crimes Enforcement Network (“FinCEN”) announced settlement agreements with Bittrex, Inc. (“Bittrex”), a cryptocurrency exchange based in Bellevue, WA.  As part of its settlement with OFAC,...

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