Category: General

OFAC Reaches Settlement with Cryptocurrency Company CoinList for Violations of Ukraine/Russia Sanctions

Matt Stankiewicz, Partner at The Volkov Law Group, provides an update on the latest OFAC action against CoinList. Matt can be reached at [email protected]. On December 13, 2023, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) announced an enforcement action against CoinList Markets LLC (“CoinList”) for violations of the Ukraine-/Russia-Related sanctions.  Between April 2020 and May 2022, CoinList processed 989 transactions on behalf...

Biden Administration Issues New Guidance for Freight Forwarders

By: Daniela Melendez (Associate at The Volkov Law Group) and Alex Cotoia (Regulatory Compliance Manager) New guidance from the Biden Administration mandates that freight forwarders are responsible for complying with trade sanctions and export compliance. On December 11, 2023, the Biden Administration released a 10-page sanctions advisory (“advisory note”) detailing the critical role that freight forwarders occupy in maintaining compliant supply chains. The advisory note...

Nasdaq Settles Iran Sanctions Violations for Pennies on the Dollar, Thanks to Voluntary Disclosure

When it comes to OFAC sanctions violations, honesty is the best policy. Promptly and voluntarily disclosing violations upon their discovery can pay serious dividends. So was the case for Nasdaq, Inc., which this week settled Iran sanctions violations in what could have been a $458 million OFAC penalty, for just $4.04 million, less than 1% of the applicable statutory maximum.  For those who view compliance...

Lessons Learned from Binance’s Criminal Settlement (III of III)

Matt Stankiewicz, Partner at The Volkov Law Group, finishes his series on Binance by providing key takeaways for AML compliance programs. Matt can be reached at [email protected]. Binance’s $4.3 billion fine is one of the largest penalties the DOJ has ever obtained from a corporate defendant.  Furthermore, its founder and CEO Changpeng Zhao (“CZ”) was also personally subject to a fine, amounting to $150 million. ...

Binance Intentionally Avoided Compliance with U.S. Laws Under CEO Changpeng Zhao (II of III)

Matt Stankiewicz, Partner at The Volkov Law Group, continues his series of posts breaking down Binance’s recent criminal settlement. Matt can be reached at [email protected]. Binance’s settlement with the DOJ represents one of the largest criminal corporate enforcement actions ever.  A review of the facts reveals that the penalty is likely warranted, as the misconduct was driven from the very top.  Binance’s founder and CEO,...

DOJ Reaches Groundbreaking Criminal Settlement with Cryptocurrency Exchange Binance and CEO Changpeng Zhao (Part I of III)

Matt Stankiewicz, Partner at The Volkov Law Group, breaks down Binance’s recent criminal settlement agreements with U.S. regulators. Matt can be reached at [email protected]. On November 21, 2023, The U.S. Department of Justice (“DOJ”) announced settlement agreements with Binance Holdings Limited (“Binance”), the world’s largest cryptocurrency exchange, and Changpeng Zhao (affectionally known as “CZ” in the cryptocurrency industry), the exchange’s founder and Chief Executive Officer...

U.S. Government Charges Parties with Violating U.S. Sanctions and Export Control Laws 

By: 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]; and Daniela Melendez, Associate at the Volkov Law Group she may be reached at [email protected] As we have repeatedly noted in the context of other blog...

Combatting Corruption: Marking the Anniversary of the Anniversary of the UN Corruption Convention’s Ratification

By: Daniela Melendez Garces, Associate at The Volkov Law Group UN Corruption Convention’s Ratification In October 2003, the General Assembly officially ratified the United Nations Convention against Corruption (“Corruption Convention”). Since that time, a total of 190 countries have ratified the Corruption Convention and agreed to be bound by its anti-corruption obligations. This marks the first time in recent history, where most of the countries...

BIS Ramps Up Antiboycott Enforcement Efforts

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 3, 2023, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) announced that a settlement had been reached with Forta —a domestic synthetic fiber...

DOJ Repeats Warnings on Aggressive Criminal Enforcement of Sanctions and Export Controls

As everyone knows, I tend to repeat myself — DOJ does as well.  Over the past year, DOJ has warned global companies — over and over — about the coming criminal enforcement storm against companies for sanctions and export control violations.  Deputy Attorney General Monaco coined the phrase — “the new FCPA,” to reiterate that companies would be prosecuted akin to FCPA enforcement, meaning that...