Category: General

23 Sep, 2025

OFAC Penalizes ShapeShift AG $750,000 for Apparent Sanctions Violations

On September 22, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced the resolution of an enforcement action against ShapeShift AG (“ShapeShift”), a now defunct digital asset exchange incorporated in Switzerland but headquartered and operated from Denver, Colorado. ShapeShift agreed to remit $750,000 to settle its potential civil liability for apparent violations of multiple U.S. sanctions programs, including those directed...

General

22 Sep, 2025

EU Clarifies Ownership and Control Standards in New Sanctions Guidance

The European Union has continued to refine its approach to sanctions compliance by publishing new guidance on the critical issues of “ownership” and “control” through its Sanctions Helpdesk platform. The guidance—released in late August 2025—offers much-needed clarity on how companies operating within the Union should identify, evaluate, and manage the risks posed by indirect links to sanctioned parties. In particular, the document provides detailed direction...

General

17 Sep, 2025

The Ever-Evolving Framework for Third-Party Risk Management

Compliance has its lingo — and one particular one I like, Third-Party Risk Management or “TPRM.” Years ago, everyone cited third-party risks. Now, we use TPRM as if everyone knows exactly what it stands for. The language usually evolves with the substance. And that is certainly true. The coverage of third-party risk has expanded with the years to embrace many new risks, issues and challenges....

General

11 Sep, 2025

DOJ Settles Two False Claims Act Cases for Evasion of Customs Duties

The Trump Justice Department has fully embraced the False Claims Act, stretching its use to include trade enforcement. DOJ recognizes the power of the FCA, the issues at stake, and the ability to extract large settlements. DOJ has used the FCA to capture companies that evade customs duties. DOJ’s recent actions are a reminder for import companies to carefully scrutinize valuation and customs duties to...

General

10 Sep, 2025

BIS Final Rule Relaxes Export Controls on Syria

In a final rule scheduled for publication in the Federal Register on September 2, 2025, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) formally implemented sweeping changes to the Export Administration Regulations (“EAR”) as they pertain to the Syrian Arab Republic. The action follows Executive Order 14312, Providing for the Revocation of Syria Sanctions, issued on June 30, 2025, in which the...

General

9 Sep, 2025

OFAC Penalizes Freight Forwarder Fracht FWO $1.6 Million for Multiple Violations of Sanctions Programs

On September 3, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced a $1,610,775 settlement with Fracht FWO Inc. (“Fracht”), an international freight forwarder headquartered in Houston, Texas, in connection with apparent violations of multiple U.S. sanctions programs, including those targeting Venezuela and Iran. The matter arose from a May 2022 transaction in which Fracht, responding to urgent customer demands,...

General

2 Sep, 2025

Checking In with Trump’s DOJ On Antitrust Enforcement

The Trump Administration’s handling of antitrust enforcement issues is generally viewed as a wild-card — meaning there are issues of concern or focus that may not fit the “traditional” antitrust enforcement model. Depending on the issue and the players, DOJ’s antitrust interest may surprise various practitioners and commentators. Trump’s nomination of Gail Slater as DOJ’s Assistant Attorney General for the Antitrust Division was universally praised...

General

25 Aug, 2025

Threat Digital Enhances its DiligenAI with Network Report Feature

With all of the hoopla and hysteria focused on AI and information systems, Threat.Digital, a long-time affiliate of The Volkov Law Group, Chris Focacci, CEO of Threat Digital, is a technology leader. Chris has the ability to explain practical application of AI technology, due diligence and information systems. He is a terrific resource and I urge all interested parties to reach out and speak with...

General

14 Aug, 2025

AI Governance Best Practices (Part II of II)

The new world of AI presents significant benefits and risks that need to be addressed in an overall governance framework. Luckily, the principles to apply here will surprise no one — governance, compliance, legal and risk professionals will quickly adapt well-known principles to the new frontier of AI. Starting at the Board level, AI oversight responsibility should be assigned a dedicated board committee, such as...

General

13 Aug, 2025

AI “Hysteria” and Legal and Compliance Risks (Part I of II)

Well, let’s all admit it — we have all enjoyed using the new, hot technology, AI. It is an understatement to opine that AI is transforming our world, business and personal. This development compares to the 1990s and the impact of the Internet. Many of us are early users of AI, finding it a welcome alternative or supplement to Internet research tools. Businesses are quickly...