Category: General

General

27 Apr, 2021

Alliance Steel Settles with OFAC for $435,003 for Violations of the Iran Sanctions Program

Alliance Steel, a US company based in Oklahoma, agreed to pay $435,003 to OFAC to settle violations of the Iran Sanctions Program.  Alliance Steel is a designer and manufacturer of prefabricated steel structures. Alliance Steel voluntarily disclosed to OFAC 61 violations of the Iran Sanctions programs. Over a five-year period, Alliance Steel maintained a professional relationship with an Iran engineering company.  The OFAV violations occurred...

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General

26 Apr, 2021

Whistleblower Protections under the Anti-Money Laundering Act of 2020

Alex Cotoia, Regulatory Manager and Compliance Consultant at the Volkov Law Group, re-joins us for a posting on whistleblower protections. Alex can be reached at [email protected]. When Congress overrode former President Donald J. Trump’s veto of the 2021 National Defense Authorization Act (“NDAA”) in January of this year, it simultaneously enacted the Anti-Money Laundering Act of 2020 (“AMLA”) into law. AMLA significantly expands upon the...

General

23 Apr, 2021

Auditors, Lawyers and the Lack of “Independence” — Bias and Financial Incentives

We are surrounded by bias in a variety of contexts –  news, politics, books and Internet information.  Given the overwhelming amount of information, some find comfort in information supplied by sources with a bias.  We have become comfortable with some level of bias.  The key is to understand the bias, the lack of objectivity and then filter the information.   Given the highly-charged political and...

General

22 Apr, 2021

Burma Sanctions and Export Licensing Prohibitions Implemented in Response to Military Coup

Recently, on April 9, 2021, the US Commerce Department’s Bureau of Industry and Security (BIS) adopted new restrictions targeting Burma by applying Export Administration Regulations’(EAR’s) military-intelligence end-use and end-user controls.  These controls were first issued in January 2021 and became effective in March 2021.  The original rule adopted in January 2021 imposed new end-use and end-user requirements, and new controls on support activities by US...

General

20 Apr, 2021

Biden Administration Ratchets Up Russia Sanctions

The Biden Administration announced new and significant trade sanctions against Russia.  The action was long expected given the Biden Administration’s criticism of Russia, and was a comprehensive response to Russia’s interference in the 2020 US election, its SolarWinds cyberattack and its ongoing occupation of Crimea and threatening addition of troops along the Ukraine border. President Biden issued a new Executive Order, No. 13848, Targeting the...

american and chinese flags and usa dollars

General

19 Apr, 2021

China’s Digital Yuan: What to Know About the First Major Central Bank Digital Currency

Matt Stankiewicz, Partner at The Volkov Law Group, rejoins us for another posting on digital currencies.  Matt can be reached at [email protected]. With the rise of digital currencies, it was inevitably going to attract the attention of governments.  Not just in the regulatory sense, but also in terms of utilization.  The blockchain technology underlying these virtual assets provide certain advantages over traditional paper money, some...

General

15 Apr, 2021

Where There is No Will, There’s No Way: The Bottom Line for Chief Compliance Officers

The Road to Hell is Paved with Good Intentions – Samuel Johnson, 1775. You can draft and design the best ethics and compliance program – and then fail.  You can show every compliance professional an “effective” set of ethics and compliance controls, pristine, drafted elegantly, addressing each and every risk with the perfectly calculated impact, and your program may fail.  Why? Paper compliance programs are...

General

13 Apr, 2021

Before Moving on to ESG, Fix Your Speak Up Culture!!

Ethics and compliance has to stand strong when new trends suddenly spring up. Organizations are always ready to embrace the new-fangled shiny object – in this case ESG.  Not to be a nattering nabob of negativism (see Spiro Agnew’s comment in 1966 crafted by William Safire), but organizations have to take a deep breath and renew a review of its ethics and compliance program fundamentals. ...

General

12 Apr, 2021

Gunvor Group Former Employee Pleads Guilty to FCPA Scheme to Pay Bribes to Ecuadoran Government Officials

Raymond Kohut, a 68-year old Canadian citizen, a former employee of Swiss commodities trader, Gunvor Group, Ltd., pleaded guilty to paying $22 million in bribes to Ecuadoran government officials at state-owned oil company, PetroEcuador. Kohut pleaded guilty to one count of money laundering conspiracy before a federal judge in Brooklyn, New York, the Eastern District of New York.  Kohut agreed to forfeit $2.2 million. Gunvor...

General

12 Apr, 2021

Volkov Law Announcements: Matt Stankiewicz is Promoted to Partner, and Ameer Gopalani, Senior Counsel, Joins the Firm

The Volkov Law Group is pleased to announce the promotion of Matt Stankiewicz to Partner, and the addition of Ameer Gopalani as Senior Counsel to the Firm. Matt Stankiewicz has distinguished himself as a seasoned and talented attorney, who is committed to integrity, ethical values and delivering high-quality, client service.  Matt joined the Volkov Law Group in 2013, while completing service as part of the...

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