History is written by the winners – Napoleon It’s never just a game when you’re winning – George Carlin On the top of its record of success, DOJ won two big and highly-contested cases. The first against Elizabeth Holmes and the second against Roger Ng. In perhaps one of its most significant failures, DOJ was handed a quick acquittal of Mark Forkner, Boeing’s Flight Technical...
Winners Never Quite and Quitters Never Win – Vince Lombardi If you fight you might lose; if you don’t, you have already lost – Bertolt Brecht Federal prosecutors know that their job – to represent the United States – is the highlight of their legal career. Speaking from experience, federal prosecutors are a privileged lot – they can announce in court they represent the United...
The Office of Foreign Asset Control’s designation of an entity as a Specially Designated National (SDN) is the “kiss of death.” Such designation not only has a direct impact on an SDN’s ability to engage in business but has a ripple effect in the global economy. Many companies not subject to OFAC regulation in the global marketplace may choose to cease or restrict business with...
SIGN UP HERE April 19 – April 22, 2022 IMPACT 2022 is the premier gathering of the year for ethics and compliance officers and practitioners who look to improve their organizational E&C initiatives while increasing efficiency and reducing costs. This year’s event features keynote addresses featuring the United States Department of Justice and the Securities and Exchange Commission. In addition, IMPACT 2022 offers more sessions...
The Antitrust Division’s Assistant Attorney General Jonathan Kanter promised a new era in antitrust enforcement. He won bi-partisan support from both Republicans and Democrats. Across the antitrust field, he promised aggressive merger enforcement, civil enforcement against digital markets, and constraint of market power in numerous industries. AAG Kanter promised a new approach and he is delivering. The annual Antitrust Spring Meeting in Washington, D.C. is...
The Biden Administration’s Department of Justice has promised aggressive white collar enforcement. On the flip side, the DOJ has recognized the importance of effective ethics and compliance programs. In an interesting speech, the Assistant Attorney General of the Criminal Division, Kenneth Polite, delivered an important speech on ethics and compliance programs. AAG Polite’s speech reiterated the importance of the Justice Department’s 2020 Evaluation of Corporate...
Matt Stankiewicz, Partner at The Volkov Law Group, joins us to discuss OFAC’s recent sanctions relating to cybercrime, darknets, and cryptocurrency. Matt can be reached at [email protected]. Continuing with both its crackdown on cybercriminals and illicit digital marketplaces, along with its continued economic pressure on the Russian Federation, OFAC has sanctioned two entities that fit both criteria. On April 5, 2022, the U.S. Treasury Department’s...
On April 6, 2022, the United States and Europe announced new sanctions on Russian banks – Sberbank, the largest bank in Russia, and Alfa Bank, another large financial institution. The new Executive Order imposes full blocking restrictions on the two banks. Sanctions were also imposed against additional Russian government officials, security officials. oligarchs and their family members. The new sanctions designated Russian President Putin’s two...
Last week, our Partner Jessica Sanderson joined a panel of outstanding women in compliance for a fireside chat hosted by ClauseMatch in honor of International Women’s Day. The group discussed current topics including crypto regulations and risk mitigation, how to maintain adequate supervision in a remote world, how to ensure the compliance function can scale with your business, how technology and AI can support a compliance program, how...
Well, we all know the familiar repetitive life experiences from the movie Groundhog Day, or as I like to say it, Déjà vu All Over Again. DOJ emphasizes over and over the importance of prosecuting individuals for criminal conduct as the key means to deter future misconduct and ensure corporate accountability. Corporations argue that imposing significant fines against them only punishes shareholders and other stakeholders...
