Corruption, Crime & Compliance

Featured Articles:

20 Jul, 2020

In Decisive Ruling, Supreme Court Rejects Trump Administration Challenges to State Criminal Grand Jury Subpoena (Part I of II)

In a decisive ruling, in Trump v. Vance, the Supreme Court rejected President Trump’s challenges to a New York State grand jury subpoena. In a 7-2 vote, The Supreme Court rejected the Trump Administration challenges. In a separate case, Trump v. Mazars, which will be analyzed in Part II tomorrow, the Supreme Court rejected challenges by a vote of 7 to 2 to Congress’ subpoena...

Podcasts

19 Jul, 2020

Episode 151 — Tom Fox and Michael Volkov Discuss the Revised FCPA Guidance

On July 2, 2020, DOJ and the SEC issued revised FCPA Guidance. The Revised Guidance continues to be a valuable document, which contains important discussions of relevant cases, DOJ and SEC policies, and enforcement principles relating to the FCPA. In this Episode, Tom Fox and Michael Volkov discuss the Revised FCPA Guidance and highlight important changes and trends.

Events

18 Jul, 2020

Webinar: 2020 Mid-Year OFAC Sanctions and Compliance Review

2020 Mid-Year OFAC Sanctions Compliance Review August 4, 2020, 12 Noon EST Sign Up Here Despite the pandemic and disruptions to the global economy, the Office of Foreign Asset Control continues its aggressive enforcement of economic sanctions. OFAC has brought several significant enforcement actions, and the Justice Department joined in one enforcement action for violation of the North Korea sanctions programs. While OFAC has recognized...

General

17 Jul, 2020

DOJ Charges Two Sons of Former Panama President Martinelli with Participation in Odebrecht Bribery Scheme in Panama

DOJ announced the arrest of two individuals, Luis Martinelli Linares and Ricardo Martinelli Linares, who are the sons of the former President of Panama, Ricardo Martinelli) for their role in funneling $28 million in bribes to a former Panamanian government official as part of the Odebrecht bribery case. Luis and Ricardo were arrested while attempting to board a private airplane at an airport in Guatemala...

General

16 Jul, 2020

Revised FCPA Guidance: Effective Compliance Program and Internal Controls (Part V of V)

The initial FCPA Guidance included valuable compliance program guidance keyed to the heading, “Hallmarks of an Effective Compliance Program.” Issued in 2012, the outline of an effective compliance program was an important statement of policy. The Revised FCPA Guidance includes additional information, some of which reflect recent changes made to the Evaluation of Corporate Compliance Programs. The Revised FCPA Guidance includes important statements on internal...

General

15 Jul, 2020

The Volkov Law Group Announces Promotions of Jessica Sanderson, Matt Stankiewicz and Noah Smith

The Volkov Law Group is pleased to announce promotions of: (i) Jessica Sanderson to Partner; (ii) Matt Stankiewicz to Managing Counsel; and (iii) Noah Smith to Senior Associate. Jessica, Matt and Noah each have distinguished themselves as terrific attorneys, who are committed to integrity and providing clients with high-quality service. Jessica Sanderson Jessica joined the firm in January 2019. She is a veteran and...

Events

15 Jul, 2020

Webinar: Jessica Sanderson and Jonathan Marks — Best Practices for Conducting Remote Internal Investigations

Webinar: Best Practices for Conducting Remote Internal Investigations July 28, 2020, 12 Noon EST Sign Up Here In this pandemic era, global companies have been challenged to maintain a reliable and effective internal investigation program. Companies have relied on remote investigation strategies to collect and review documents and conduct interviews. In conducting remote investigations, companies have to ensure that they follow investigation requirements, maintain confidentiality...

General

15 Jul, 2020

Revised FCPA Guidance: Legal Issues and Clarifications (Part IV of V)

FCPA practitioners often debate whether the FCPA is “clear” or “ambiguous.” Like all important issues in life (assuming this is important), the answer really depends on the specific language. Congress’ ability to write clear and concise statutes varies across the lot, and the FCPA includes provisions that are clear and some that, depending on the situation, may not be. The Revised FCPA Guidance addresses a...

General

14 Jul, 2020

Revised FCPA Guidance: Updated DOJ Policies (Part III of V)

The Justice Department has continued at a steady rate to tweak relevant policies applicable to FCPA enforcement. The Revised FCPA Guidance has incorporated these policies. FCPA Corporate Enforcement Policy and Declinations (pp. 51-54) The FCPA Corporate Enforcement Policy is quickly becoming “a well-established” framework. DOJ has expanded it to cover all corporate criminal resolutions except for criminal antitrust violations. The FCPA Corporate Enforcement Policy (“CEP”)...

General

13 Jul, 2020

Revised FCPA Guidance: New Case Updates (Part II of V)

Over the last eight years, FCPA litigation has increased. Companies are still avoiding the risks of litigation and losing to the Justice Department and the SEC. Individuals, on the other hand, have clear incentives to challenge DOJ’s FCPA interpretations, where appropriate, and they have done so. The Revised FCPA Guidance incorporates these new cases throughout the text and its numerous footnotes. The major additions include:...