The Volkov Law Group wishes our clients, colleagues, subscribers, readers and friends and families a wonderful, happy holiday season. We are grateful for your support and your friendship. We look forward to a New Year filled with hope, recovery, and a bright path forward. Our blog, podcasts and webinars will return after the New Year. Thank you again from all of us at The Volkov...
In May 2019, OFAC released its Framework for a Sanctions Compliance Program. OFAC announced that it intended to increase the prosecution of individuals for sanctions violations. OFAC has brought two cases against individuals, and last week settled its third case against an individual since its May 2019 announcement. The latest case involves prohibited transactions with Iran relating to the cement clinker business. The individual, a...
In an interesting announcement, the US, EU, UK and Canada implemented additional sanctions against Belarus. The coordinated announcement reflected the Biden Administration’s diplomatic commitment to joint sanctions actions. The strategy is designed to increase the impact of sanctions programs in response to President Lukashenko’s pushing of a humanitarian crisis resulting from the migrant crisis in Eastern Europe. This humanitarian crisis resulted in widespread condemnation by...
When the Department of Justice warns businesses and individuals, everyone needs to listen and respond accordingly. Starting in 2016, the Justice Department’s Antitrust Division warned businesses that the Antitrust Division intended to bring criminal prosecutions for illegal agreements, price-fixing/wage-fixing, in labor markets. No one should be surprised – DOJ has been bringing criminal cases against companies, executives and human resource professionals. In the beginning of...
The new United States Strategy on Countering Corruption includes several important statements of interest to legal and compliance professionals. Under the third of the five pillars, Holding Corrupt Actors Accountable, the U.S. Government specifically calls out the importance of private sector commitment to anti-corruption compliance programs “to improve the international business climate by encouraging the adoption and enforcement of anti-corruption compliance programs by U.S. and...
The Biden Administration’s new anti-corruption initiative is a significant commitment to the battle against global corruption. According to the Biden Administration, “[c]orruption is a cancer with the body of societies – a disease that eats at public trust and the ability of governments to deliver for their citizens. The deleterious effects of corruption impact nearly all aspects of society.” At the heart of the new...
The Biden Administration announced a new, comprehensive anti-corruption program, the United States Strategy on Countering Corruption. The new anti-corruption policy is the follow on to the earlier announcement elevating the global anti-corruption battle to a national security concern. After that announcement, the Biden Administration conducted a 200-day inter-agency examination to develop a comprehensive government-wide anti-corruption initiative. The Biden Administration released the new United States Strategy...
Alex Cotoia, Regulatory Manager and Compliance Consultant, rejoins us for a blog post of the SEC’s adoption of foreign issuer disclosure rules. Alex can be reached at [email protected]. On December 3, 2021, the U.S. Securities and Exchange Commission (“SEC”) announced the adoption of a final rule that fully implements the requirements of the Holding Foreign Companies Accountable Act (“HFCAA”) enacted by the Congress and signed...
When: December 15, 2021 Time: 2 pm to 3:30 pm EST Sign Up HERE Over the past several years the Department of Justice has periodically issued material updates to guidelines related to compliance programs and enforcement. The US Chamber of Commerce Institute for Legal Reform has underwritten an important and timely survey of ethics & compliance officers by ECI related to how they are interpreting and...
The Antitrust Division won a preliminary skirmish against two co-defendants who challenged the criminal indictment against them charging price-fixing in the labor market. District Court Judge Mazzant, in the Eastern District of Texas, issued a decision denying the defendants’ motion to dismiss in United States v. Neeraj Jindal & John Rodgers, 20-CR-358. (Here). In rejecting the defendants’ motion, the trial judge ruled that price-fixing in...
