Corruption, Crime & Compliance

Featured Articles:

16 Jun, 2019

U.S. Entities Engaged in M&A Transactions Beware; OFAC Highlights the “Unique Sanctions Risks” Posed by Foreign Acquisitions

Jessica Sanderson, Of Counsel at the Volkov Law Group, rejoins us for a posting on OFAC’s recent enforcement actions involving Expedia and other cases involving acquisitions of foreign-owned companies. Jessica can be reached at [email protected]. On June 13, 2019, OFAC announced a settlement with Expedia Group, Inc. for violations of the Cuban Assets Control Regulations (“CACR”). (Available here). Expedia’s foreign subsidiaries assisted more than 2,200...

Podcasts

16 Jun, 2019

Episode 94 — How to Conduct a Risk Assessment for Sanctions Compliance

OFAC’s new framework guidance for sanctions compliance programs stretched into new territory with its risk assessment requirement. This new approach reflects OFAC’s recent aggressive enforcement programs. The scope of a risk assessment has to mirror the breadth of enforcement risks and has to include review of: (i) customers, supply chain, intermediaries, and counter-parties; (ii) the products and services it offers, including how and where such items fit into...

General

13 Jun, 2019

Operationalizing Your Compliance Program: Local Compliance Officers and Businesses

The Justice Potter Stewart phrase, “You know it when you see it,” applies to life issues and even compliance. Global companies struggle with program design, allocation of resources (e.g. human resources and money/assets), and program operation. We all hear (and repeat ourselves) “no-one-size-fits-all” when addressing specific recommendations on how to design and implement a global ethics compliance program. But that does not mean that certain...

General

12 Jun, 2019

OFAC Fines US Company for Iran Sanctions Violations

There is no question that OFAC continues to dominate the enforcement landscape this year. OFAC has provided plenty of warning and notice to global companies, especially those in the manufacturing and industrial sectors. OFAC has exercised its prosecutorial discretion to underscore the risks global companies face in their distribution channel, i.e. use of third party distributors, and in its supply chain. These twin risk areas...

General

12 Jun, 2019

Commerce Department Blocks Export Licenses to Huawei Technologies Co., Ltd.

In a controversial decision, on May 15, 2019, the US Commerce Department announced the addition of Huawei Technologies Co., Ltd. (“Huawei”) and 68 affiliates to its Entity List. As a result, export licenses for Huawei are subject to a presumption of denial. The Commerce Department cited a number of reasons for its decision, including alleged violations of the International Emergency Economic Powers Act (IEEPA), conspiracy...

General

11 Jun, 2019

Michael Volkov Releases New E-Book: The Road Ahead — The Justice Department’s Path to a Balanced White-Collar Enforcement Policy

I am pleased to announce the release of my new e-book: The Road Ahead: The Justice Department’s Path to a Balanced White-Collar Enforcement Policy. The new e-book can be downloaded HERE. Thanks to Corporate Compliance Insights for publishing the book and its continuing support. The Justice Department’s FCPA Corporate Enforcement Policy, adopted in November 2017, was a watershed moment in criminal justice. Over the last...

General

10 Jun, 2019

Telefônica Brasil Pays $4.125 Million for Hospitality-Related FCPA Violations

As the old adage provides – better late than never. (Same applies for my somewhat tardy posting on this case). Telefônica Brasil settled FCPA violations with the SEC for a pretty penny — $4.125 million in civil penalties in connection its hospitality program for the 2014 World Cup and 2013 Confederations Cup According to the settlement agreement, Telefônica Brasil failed to maintain adequate internal controls...

Podcasts

9 Jun, 2019

Episode 93 — Matt Stankiewicz Discusses Data Privacy on Blockchain with ImagineBC CEO Erik Rind

Data privacy has become a hot topic lately. Companies have built massive fortunes by selling users’ personal information to the highest bidder. Meanwhile, they often fail to secure that same data while hackers run amok, putting the users at risk. What’s a person to do? Enter ImagineBC. In the ImagineBC community, you’re in control of your personal information – and free to monetize it. Built on...

General

8 Jun, 2019

Free Webinar Recording: ITAR Compliance: Navigating Complex Risks

On June 5, 2019, The Volkov Law Group conducted a webinar on ITAR Compliance: Navigating Complex Risks. A free recording of the webinar is here. Mike can be contacted at [email protected].

Events

8 Jun, 2019

Webinar: Achieving an Effective Compliance Program: DOJ and OFAC Guidance, Best Practices, and Industry Trends

Webinar: Achieving an Effective Compliance Program: DOJ and OFAC Guidance, Best Practices and Industry Trends June 25, 2019, 12 Noon EST SIGN UP HERE The compliance industry is evolving. Recent DOJ and OFAC Guidance are just one influence. At the same technology and innovative strategies using data analytics are quickly eclipsing government guidance, especially in the area of compliance program monitoring, testing and auditing. Companies...