Alex Cotoia, Regulatory Manager at The Volkov Law Group, rejoins us for an important posting on new Commerce Department rules relating to computer product exports to China. Alex can be reached at [email protected]. On October 13, 2022, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) published an interim final rule that significantly expanded export controls designed to thwart China’s efforts to acquire...

Alex Cotoia, Regulatory Manager at The Volkov Law Group, rejoins us for a review of OFAC’s recent settlement with Tango Card for sanctions violations. Alex can be reached at [email protected]. On September 30, 2022, the United States Department of the Treasury’s Office of Foreign Asset Control (“OFAC”) announced a settlement with Tango Card, Inc. (“Tango Card”), a supplier and distributor of stored valued cards used...

The Office of Foreign Assets Control (“OFAC”) has demonstrated its ability to multi-task — designing, implementing and enforcing a comprehensive sanctions regime against Russia after its invasion of Ukraine, and maintaining its “regular” enforcement program. In a recent two-fisted settlement, OFAC reached two separate settlements with Credit Agricole companies.  First, OFAC reached a settlement with Credit Indosuez Switzerland S.A. (“CAIS”), an indirect subsidiary of Swiss-based...

In a significant action, the Justice Department brought criminal charges against the notorious Russian Oligarch, Oleg Deripaska, for sanctions evasion and obstruction of justice.  DOJ also charged three associates, Natalya Bardakova, a Russian citizen, Olga Shriki, a New Jersey resident and United States citizen, and Ekaterina Voronina, Deripaska’s girlfriend.  Shriki is also charged with obstruction of justice for deleting various electronic records after she received...

Oracle’s SEC settlement for $23 million underscores the power of the FCPA provisions mandating effective internal controls and accurate books and records.  As everyone knows, these provisions can be applied to a wide-range of conduct beyond foreign bribery.  The SEC recognizes the power of these provisions and have used them in a variety of settings. Oracle has now fallen under the enforcement sword twice —...