Category: General

DOJ Raises Stakes on Corporate Compliance Programs – Accountability and Certifications

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...

OFAC Focuses on Cybercrime by Sanctioning the Hydra Darknet Market and GARANTEX Cryptocurrency Exchange

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...

United States and Europe Ramp Up Sanctions Against Russia and Target Sberbank, Alfa Bank and “New Investments”

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...

Jessica Sanderson Participates in Women in Compliance Event

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...

DOJ’s Focus on Prosecution of White Collar Criminals

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...

OFAC Settles with S&P Global for $78,750 for Violations of Ukraine-Russia Sanctions Program

Prosecutors and regulators are scouring their files for enforcement actions – criminal and civil – for violations of the 2014 Ukraine-Russia Sanctions Program.  The message being sent is clear – do not violate any sanctions against Russia, whether the initial round of restrictions in 2014 in response to Russia’s annexation of Crimea, or the broader sanctions recently implemented in response to Russia’s broader invasion of...

DOJ’s Antitrust Chief Outlines Aggressive Approach to Enforcement Against Digital Market Companies

A new traffic cop is presiding over the global economy.  This is not a surprise.  Aggressive antitrust enforcement is now bi-partisan, and the first target – digital markets has been the focus of both Democrats and Republicans. Jonathan Kanter, the new Assistant Attorney General for the Antitrust Division, gave an important speech at an international meeting outlining the theoretical underpinning of the need for robust...

US Coal Company VP Arrested and Charged with FCPA, Money Laundering and Wire Fraud Violations

The Justice Department announced the arrest and indictment of Charles Hunter Hobson for violating the FCPA, money laundering and receiving kickbacks arising from a bribery scheme to pay government officials in Egypt in exchange for contracts for coke and chemicals with Al Nasr, an Egyptian state-owned company. Last year, Frederick Cushmore, the former VP and head of International Sales at Corsa Coal Corporation, pleaded guilty...

DOJ Issues Declination to Global Insurance Company Under FCPA Enforcement Policy

The Justice Department continues its enforcement “silence” with no major corporate prosecutions announced this year.  It is an interesting question but it appears that the wheels have ground to a halt, with one major exception – prosecutors are bringing cases against individuals.  Inside the Justice Department corporate criminal FCPA enforcement has been held up. For FCPA practitioners and commentators, that leaves individual cases and corporate...

Putin’s Puppets Pick on Peppa Pig: Intellectual property rights are collateral damage in the economic war between Russia and the nations supporting Ukraine

Jessica Sanderson, Partner at The Volkov Law Group, joins us for an interesting posting on the impact of Russia sanctions on intellectual property. Jessica can be reached at [email protected]. As we’ve reported elsewhere in our blog, the U.S., EU, and other nations recently have enacted significant economic sanctions against Russian individuals and entities in response to Russia’s invasion of Ukraine. Russia is striking back, and...