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Happy Fourth of July!!

To all of our clients, colleagues, family and friends, we wish you a Happy Fourth of July. While we live in a difficult and troubling time, please take a moment to embrace gratitude and respect for all those who have sacrificed to secure our freedoms. Together, we can continue America’s unique history of freedom. Have a terrific holiday!!

CCOs and Execution of Compliance Certification: A Significant Risk? (Part III of III)

CCOs, by definition, are careful and deliberate.  It comes with the profession.  As risk managers, CCOs are skilled in identifying, assessing and acting in a risk environment. The impact of the new CCO certification requirement, however, presents serious risks that cannot be brushed off or ignored in the face of assurances that prosecutorial discretion will protect CCOs from misguided prosecutions.  Frankly, CCOs recognize that there...

DOJ CCO Certification Requirements and DOJ Compliance Mandates (Part II of III)

The new DOJ Certification requirements certainly raise a number of new issues and risks for senior management and chief compliance officers.  In Part I of this series, I outlined the specific language and the Plea Agreement standards imposed on companies that enter into a Plea Agreement with DOJ for FCPA violations. DOJ has reiterated its support for this new Certification requirement.  Indeed, a DOJ official...

DOJ Compliance Program Certification Requirements (Part I of III)

The Department of Justice continues to respond to the compliance community’s concerns about the new certification requirement adopted as part of the Glencore FCPA enforcement action.  DOJ has adopted this new requirement to “empower” CCOs and to ensure that CCOs have a “seat at the [senior management] table.”  While these are all laudable goals, CCOs continue to question whether DOJ’s new certification requirement will undermine...

Episode 239 — DOJ’s New CCO Certification Requirement

The Department of Justice continues to respond to the compliance community’s concerns about the new certification requirement adopted as part of the Glencore FCPA enforcement action. DOJ has adopted this new requirement to “empower” CCOs and to ensure that CCOs have a “seat at the [senior management] table.” While these are all laudable goals, CCOs continue to question whether DOJ’s new certification requirement will undermine their authority...

Sanctions in the Twenty-First Century: UK Imposes Social Media Restrictions in Response to Continued Russian Aggression

Alex Cotia, Regulatory Manager and Compliance Adviser at The Volkov Law Group, rejoins us for a post on the United Kingdom’s Russia Sanctions against social media. Alex can be reached at [email protected] Under a statutory instrument promulgated under the Sanctions and Anti-Money Laundering Act 2018 (amending the Russia (Sanctions) (EU Exit) Regulations 2019)), the UK government recently passed sweeping new trade restrictions on the provision...

Department of Commerce’s Bureau of Industry and Security Charges Russian Oligarch Abramovich with Violating Russia Export Controls

The Department of Commerce’s Bureau of Industry and Security (“BIS”) charged Russian oligarch Roman Abramovich with violating U.S. export controls by exporting U.S.-origin aircraft to Russia.  In a precedent setting action, BIS issued a charging letter, the first letter under a new enforcement policy, outlining the specific facts in support of the charges. As described in the charging letter, two of Abramovich’s private planes flew...

Human Rights and Supply Chain Risks: The Uyghur Forced Labor Prevention Act (Part II of II)

The Volkov Law Group is pleased to publish this blog article written by our summer intern Victoria Rinn, a rising junior at Cornell University. After researching the law and attending a U.S. Customs and Border Protection webinar on June 16, 2022, Victoria discusses the Uyghur Forced Labor Prevention Act, which took effect on June 21, 2022, and the impact on private companies’ supply chains. On...

Private Attorneys General: Enforcing Human Rights Through Corporate Supply Chain and Risk Management (Part I of II)

The Volkov Law Group is pleased to announce our first, official summer internship program. We have welcomed a diverse group of talented, intelligent, and driven college students, who are interested in pursuing legal or compliance careers. In this blog article, our intern Abigail Schuman, a rising junior at the University of Wisconsin, discusses certain legislation aimed at combatting slave labor and human trafficking in corporate...

Episode 238: 2022 FCPA Enforcement Trends . . . So Far

In following the Justice Department and the Securities Exchange Commission FCPA enforcement actions, I am always reminded of the popular phrase — “reading the tea leaves.” (or “tasseography,” a fortune-telling method based on tea leave patterns in tea sediments). Despite a slow initial year in 2021, the Biden Administration’s stamp and push on FCPA enforcement is becoming clear.  Keep in mind, DOJ and SEC officials have...