Elizabeth Slim, Senior Consultant at The Volkov Law Group joins us for an important posting on OFAC sanctions compliance as a result of the pandemic. Elizabeth can be reached at [email protected]. It was only a matter of time before regulators and law enforcement recognized the impact that the pandemic has had on our country and our economy – The Office of Foreign Assets Control (“OFAC”)...
Despite the COVID-19 pandemic crisis, the SEC is continuing its FCPA enforcement activities. The SEC lawyers and staff have brought two cases recently – an enforcement action against a former Goldman Sachs executive and the settlement with ENI which was announced on Friday. HERE. During the relevant period, between 2007 and 2010, ENI held a 43 percent minority-control interest in Saipem S.p.A. ENI’s American Depositary...
Last week, the Securities and Exchange Commission (“SEC”) filed charges against Asante Berko, a former Goldman Sachs executive with bribery of foreign government officials in Ghana. Goldman Sachs discovered and stopped the scheme and then reported it to the government. Goldman Sachs was not charged with the conduct and cooperated with the investigation. The SEC’s complaint charged Berko with assisting a client, a Turkish energy...
When Congress enacts massive financial relief legislation, one inevitable result is fraud, waste and abuse. Going back to the financial crisis in 2008, DOJ had a trove of criminal fraud and civil fraud cases under the False Claims Act. With the passage of the CARES Act, you can count on DOJ ramping up criminal and civil fraud prosecutions, especially under the False Claims Act. The...
Tom Fox and I recently got together for a five-part series on COVID-19 and compliance issues. Here are the episodes and links: Part 1: Business Ethics Matter Even More Now — HERE Part 2: Board of Directors and Crisis Management — HERE Part 3: Why Compliance Never Sleeps — HERE Part 4: The Role of the CCO — HERE Part 5: Leadership and Final Thoughts...
Webinar 10 am EST/3 pm BST April 29, 2020 Sign Up HERE As the world fights COVID-19 and compliance officers grapple with virtual working at this time of heightened risk, are they increasingly seeking digital and automated processes to succeed? This webinar considers why the current climate has heightened awareness of the advantages of digital and automated compliance practice. Join this webinar to: hear how implementing...
Jessica Sanderson, Of Counsel, The Volkov Law Group, rejoins us for a posting on the importance of compliance during the COVID-19 pandemic. Jessica can be reached at [email protected]. In these challenging times, when governments around the world are asking all “non-essential” workers to stay home, and companies are struggling with business interruptions and difficult decisions regarding pay-cuts, layoffs and furloughs, we’ve been thinking a lot...
Despite the COVID-19 pandemic, the SEC entered into a settlement with Eni for $24.5 million for FCPA violations. In another matter, the SEC filed an FCPA case against a former Goldman Sachs executive for bribery in connection with business on behalf of a client in Ghana. In this episode, Michael Volkov reviews these two enforcement actions.
It turns out law school was very helpful to practicing law – every first year law student is required to take a contract law class. Now, lawyers are able to apply what they learned in the most unlikely of circumstances – the Covid-19 pandemic. Companies suffering from the shelter in place and business disruptions have to identify and assess liability under contracts with vendors, suppliers...
Jonathan Marks, Partner, Baker Tilly, joins us for a posting on the importance of corporate board oversight of ethics and compliance programs. Jonathan’s profile is here and his email contact is [email protected]. Under the U.S. Federal Sentencing Guidelines, in order to receive credit for having an effective compliance program, and thereby reduce the fines imposed on the organization, a Board of Directors must be “knowledgeable...
