Category: General

BIS and FinCEN Release Joint Notice Concerning Global Export Control Evasion 

Alexander J. Cotoia currently serves as the Regulatory Compliance Manager at The Volkov Law Group, where he regularly advises the firm and its clients on the latest developments implicating trade compliance concerns. He may be reached at [email protected]. On November 6, 2023, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) and the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) released...

Justice Department Declines FCPA Prosecution Against Lifecore Biomedical Under Corporate Enforcement Policy

The Justice Department has brought three corporate FCPA enforcement actions in 2023 (if you include the Ericsson DPA breach settlement).  With its recent announcement of a declination under the Corporate Enforcement Policy, DOJ has declined two FCPA cases and one healthcare fraud case in 2023. DOJ publicizes the declination letters issued in accordance with the Corporate Enforcement Policy.  DOJ officials have made numerous public statements...

SEC and DOJ Charge SafeMoon Cryptocurrency and its Executives For Multi-Million Dollar Fraud

Matt Stankiewicz, Partner at The Volkov Law Group, provides a post on the latest fraud charges in the cryptocurrency industry, brought against SafeMoon. Matt can be reached at [email protected]. On November 1, 2023, the U.S. Department of Justice (“DOJ”) and U.S. Securities and Exchange Commission (“SEC”) brought charges against cryptocurrency project SafeMoon LLC and its U.S. subsidiary SafeMoon US LLC, along with its three executives,...

The EU Corporate Sustainability Reporting Directive is (Almost) Here. Is Your Company Ready?

On January 1, 2024, the long-awaited EU Corporate Sustainability Reporting Directive (“CSRD”) begins to take effect. The CSRD is intended to redefine corporate social responsibility expectations for both in-scope companies and out-of-scope third-parties with whom they transact. This regulatory overhaul concentrates enforcement efforts on global supply chains, requiring in-scope companies to take an active role in safeguarding human rights not just within their own operations,...

DOJ’s Latest Opinion Release Underscores Absence of Corrupt Intent and Lack of Business Purpose

The Justice Department has had a slow year in FCPA enforcement (another profound grasp of the obvious).  The reasons for this may be a question of timing elements in the pipeline of cases.  What is clear is that pushing through an enforcement action and settlement requires increased coordination with a growing number of international partners.  That may be part of the explanation. In this environment,...

Gan Integrity and Control Risks Webinar: From Compliance to Sustainability

From Compliance to Sustainability December 6, 2023 10 am EST/4 pm CET SIGN UP HERE Gan Integrity and Control Risks have announced an important upcoming webinar addressing the evolving third-party risk management context — From Compliance to Sustainability. Third-party risk management has evolved at a rapid pace over the past decade. The regulatory environment has quickly followed suit. Enterprises, however, are struggling to keep up...

Avoiding the Misclassification Mess—Practical Solutions for Managing Your Trade Compliance Program

Alexander J. Cotoia currently serves as the Regulatory Compliance Manager at The Volkov Law Group, where he regularly advises the firm and its clients on the latest developments implicating trade compliance concerns. He may be reached at [email protected]. Recent comments from the top leadership of both the Directorate of Defense Trade Controls (“DDTC”) and Bureau of Industry and Security (“BIS”) during a government and defense...

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A pesar del alivio en materia de sanciones comerciales por parte del gobierno de EE.UU al sector del petróleo y gas en Venezuela todavía hay retos por superar

Matt Stankiewicz, socio en The Volkov Law Group PC, se une otra vez a nuestro blog para discutir el context del Alivio de las sanciones en Venezuela por parte del gobierno de EEUU. Matt lo pueden contactar en [email protected].  Este blog fue traducido por: Daniela Melendez, la pueden contactar en [email protected]. Como lo mencionamos en nuestro artículo la semana pasada, la Oficina de Control de...

OFAC Settlement with DaVinci Payments Is Wake-Up Call for Prepaid Access Industry

Rewards programs have become ubiquitous in recent years. These so-called loyalty management programs exist to nudge customers or employees in a particular direction; a company’s workers might be inclined to exercise more regularly, for example, if they know there is a $5 gift card waiting for them after a specified number of gym check-ins. Their rapid expansion and cash-equivalent, pre-paid nature make loyalty management programs...

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Despite OFAC Sanctions Relief, the Venezuelan Oil and Gas Industry Still Presents Risks

Matt Stankiewicz, Partner at The Volkov Law Group PC, provides important context regarding OFAC’s new General Licenses under the Venezuela Sanctions Program. Matt can be reached at [email protected]. As we discussed previously, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) recently provided Venezuela with much needed sanctions relief.  Specifically, OFAC issued General License 44 (among others) that broadly authorizes transactions related to...