The success of a compliance program depends on a number of factors.  Perhaps one of the most important factors is the strength of the relationship between compliance professionals and business.  Compliance depends on business employees to share information, coordinate in compliance procedures, and ensuring overall compliance. As one business manager candidly told me during a risk assessment interview, “if business does not take responsibility for...

UniControl, Inc., a Cleveland, Ohio manufacturer of process controls, airflow pressure switches, boiler controls and other instruments, agreed to pay OFAC $216,464 to settle its liabilities for violation of the Iran Sanctions Program.  UniControl exported 19 shipments of its goods to two European countries with reason to know that the goods were intended for delivery to Iran end users.  In addition, UniControl exported two shipments...

Chief compliance officers (CCOs) are talented professionals.  As Donna Boehme always emphasizes, CCOs are subject matter experts (SMEs) in compliance risks, controls and mitigation.  CCOs focus on legal and compliance risks as reflected in an organization’s Code of Conduct, ethical culture and legal requirements.  In recognition of their unique role in every organization, CCOs have line of sight across the organization, independence and authority to...

Matt Stankiewicz, Managing Counsel at The Volkov Law Group, joins us for a post looking into the CFTC’s recent inquiry into Binance. Matt can be contacted at [email protected]. On Friday March 12, Bloomberg News reported that the Commodity Futures Trading Commission (“CFTC”) has opened an inquiry into Binance Holdings Ltd. (“Binance”) to investigate allegations that the exchange allowed US citizens to trade in cryptocurrency derivatives,...

I had the pleasure of participating in a recent webcast sponsored by ClauseMatch, an innovative automated policy management and compliance platform. The panel included: Evgeny Likhoded, CEO and Founder of ClauseMatch Doreen Ghusar, Senior Director of regulatory Compliance at Roostify Rachel Woolley, Global Director of Financial Crime at Fenergo Our discussion focused on compliance trends, technology and evolution of the compliance profession. You can watch...

President Biden signed an Executive Order on America’s Supply Chains, E.O. 14017, which initiates a 10-day period to review the strength of United States supply chains for four specific sectors.  The purpose of the Executive Order is to address weaknesses in, and shortages of, critical supplies in order to prevent future crises from dependency on adverse foreign suppliers.  As part of the review, the Biden...

Blog after blog, commentator after commentator, and everyone else who has an opinion has been repeating the same message – the Biden Administration is going to increase enforcement risks.  While these general opinions are correct, a more specific and focused analysis is needed. It is one thing to cite a strong enforcement bent but it is another to watch the key issue – resources.  I...

The SolarWinds cyber-attack was devastating in scope and impact. If any lesson can be learned from this event, the SolarWinds case presents all the pitfalls, enforcement and reputational damage, rolled into one tragic series of events. In a recent 10-K disclosure, SolarWinds announced that it is the subject of ongoing investigations conducted by the Department of Justice, the Securities and Exchange Commission, and various state...

There is much to be learned from reviewing the wreckage of a major Justice Department enforcement action.  It is helpful to identify these themes, analyze the conduct and reasons for the violation, and identify helpful insights that can be applied to your company or project.  Two significant enforcement actions in 2020 highlighted an important issue that lies at the heart of every company’s culture, especially...