Featured Articles:

UFLPA in Focus: Lessons to Be Learned from Volkswagen’s Recent Experience

News recently published by multiple media outlets suggest that certain subcomponents incorporated into a variety of Volkswagen-owned vehicles—including cars manufactured by luxe brands Porsche, Bentley and Audi—were sourced from an unspecified region in “western China” (“PRC”) presumed to be the Xinjiang Uyghur Autonomous Region (“XUAR”). According to these sources, Volkswagen itself was not aware of the origin of the part, which, according to the Financial...

Episode 309 — Alex Cotoia on Compliance with Uyghur Forced Labor Prevention Act

On December 31, 2021, President Joseph R. Biden, Jr. signed the the Uyghur Forced Labor Prevention Act (“UFLPA”) into law to address the ongoing exploitation of the ethnic minority Uyghur population by the government of the People’s Republic of China (“PRC”). Among other things, the UFLPA creates a rebuttable presumption that all goods, wares, articles, and merchandise mined, produced, or manufactured wholly or in part...

Preparing for the Storm — Effective Compliance in the New Sanctions Era (Part II of II)

If companies operated with perfect governance mechanisms and controls, they would all be ready for the coming sanctions enforcement storm.  However, that is not the corporate reality.  Even after several companies are the subjects of these aggressive enforcement actions, corporate boards, senior risk managers and senior executives will turn to the chief compliance officer and ask — “do we have an effective sanctions compliance program?”...

The Coming Corporate Sanctions Enforcement Storm (Part I of II)

There are some things you learn best in calm, and some in storm.  Willa Cather I know I sound like a broken record.  The Justice Department’s white collar criminal enforcement  has been trending down over the last few years.  The reasons for that are unclear — is it resources, difficulty and length of investigations or just lack of initiative?  Whatever the cause may be, one...

New Executive Order Prohibitions Targets Violence in West Bank 

On February 1, 2024, President Joseph R. Biden, Jr. promulgated Executive Order 14115 (“E.O. 14115), the effect of which is to impose economic sanctions on individuals ostensibly contributing to gratuitous violence and political unrest in the West Bank. Finding that the “situation in the West Bank” involved unacceptably “high levels of extremist settler violence, forced displacement of people and villages, and property destruction,” the President...

Episode 308 — Gabrielle Griffith, Director BPE Global, on Trade Compliance Trends and Expectations

Gabrielle Griffith, Director BPE Global, is an expert in trade compliance issues. Gabrielle assists clients in implementing effective trade compliance programs by addressing improvements within organizations’ people, processes, and systems. In the area of U.S. export controls, she advises clients on compliance with the International Traffic in Arms Regulations, the U.S. Export Administration Regulations, and the various embargo and sanctions programs administered by the Office...

Licencia 43a: reimposición de sanciones en Venezuela

Por: Matt Stankiewicz socio en Volkov Law Group ([email protected]) y Daniela Melendez asociada en Volkov Law Group ([email protected]) El 18 de octubre de 2023, la Oficina de Control de Activos Extranjeros (“OFAC”) del Departamento del Tesoro de los Estados Unidos tomó varias medidas para proporcionarle a Venezuela un alivio limitado a las sanciones económicas impuestas. El alivio incluyó Licencias Generales que autorizaban transacciones y negocios...

OFAC Begins to Roll Back Venezuelan Sanctions Relief, Again Prohibiting Transactions with CVG Minerven

Matt Stankiewicz, Partner, and Daniela Melendez, Associate, provide key updates on the Venezuela Sanctions Program. Matt can be reached at [email protected] and Daniela can be reached at [email protected]. Easy come, easy go.  On January 29, 2024, OFAC published General License 43A under the Venezuela Sanctions Regulations, which partially rolled back a piece of the sanctions relief it provided to the country only a few months prior. ...

BIS Imposes $153,175 Penalty Against Wabtec Corporation to Resolve Multiple Violations of Antiboycott Regulations

By: Alex Cotoia, Regulatory Compliance Manager at the Volkov Law Group ([email protected]) and Daniela Melendez, Associate at the Volkov Law Group ([email protected]) Wabtec Corporation (“Wabtec”)—a global manufacturer and supplier of rail technology headquartered in Pittsburgh, Pennsylvania—recently settled an administrative enforcement proceeding with the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) involving forty-three (43) apparent violations of the antiboycott provisions of the Export...

DOJ’s New Mantra — Data and Detection

The technology revolution and the rise of information and data permeates every aspect of our economy and daily lives.  It is not surprising then that the Department of Justice and other law enforcement agencies are embracing data analytics as a new enforcement tool.  DOJ is fast embracing data as a new and valuable source of detection. When DOJ issues a grand jury subpoena, this is...