Stanley Black and Decker (“Stanley”) and its Chinese subsidiary Jiangsu Guoqiang Tools Co. (“GQ”) agreed to pay approximately $1.9 million to settle OFAC charges that it violated the Iran Sanctions Program. The OFAC enforcement action was the fifth in 2019. Stanley voluntarily disclosed the apparent violations to OFAC. See Here for a copy of OFAC Enforcement Action. Between June 2013 and December 2014, GQ exported...
The Justice Department is wedded to its FCPA Corporate Enforcement Policy (excuse me for the use of “wedded,” we recently celebrated our son’s wedding). Nonetheless, DOJ has to adjust its Policy in response to experience and feedback. That is a good thing and one that helps to ensure that the Policy is predictable and consistent in its application. I am convinced that the FCPA Corporate...
Matt Stankiewicz rejoins us for another posting on cryptocurrency compliance. Matt can be reached at [email protected]. Just this month, former CFTC Chairman Timothy G. Massad released a report through the Brookings Institution entitled “It’s Time to Strengthen the Regulation of Crypto-Assets.” Interestingly enough, Mr. Massad was at the helm of the CFTC during the financial crisis. He even notes that he “share[s] the desire to...
In the first corporate FCPA action of 2019, Cognizant Technology Solutions Company settled its long-running FCPA case, agreeing to pay the SEC $25 million. At the same time, the Justice Department announced: (1) its’ declination under the FCPA Corporate Enforcement Policy; and (2) the indictment of Cognizant’s former President and General Counsel for criminal FCPA violations. In this Episode, Michael Volkov discusses the Cognizant FCPA...
And now we return to a familiar theme with some important updates – I always start with the simple proposition: ethical companies perform better over the long run; that does not mean that ethical companies will always be profitable, but it does mean that ethical companies will perform better than they would otherwise perform. Some call this the ethical advantage or the ethical premium. I...
Webinar: Top 3 Areas for Anti-Corruption Compliance April 11, 2019, 2 PM EST SIGN UP HERE As corruption risks increase, are you aware of the top 3 focus areas for compliance? Thomson Reuters is pleased to offer a webinar conducted by Julie DiMauro, Regulatory Intelligence Expert, and Michael Volkov, CEO at The Volkov Group focused on the top-3 issues for anti-corruption compliance. Global anti-corruption risks...
There is nothing training cannot do. Nothing is above its reach. It can turn bad morals to good; it can destroy bad principles and recreate good ones; it can lift men to ‘angel ship. – Mark Twain I am always struck by how much is written about tone-at-the-top, board commitment to compliance and specific benchmarking of chief compliance officer access and reporting to a corporate...
In a shocking announcement, federal prosecutors announced the arrest and charges against numerous individuals in connection with a nationwide criminal investigation focusing on college entrance exam cheating and admission of students to elite universities as fake athletic recruits. Athletic coaches from Yale, Stanford, USC, Wake Forest and Georgetown, as well as parents and exam administrators have been implicated. At the center of the scam was...
We spend a lot of time discussing foreign bribery. The United States has its own bribery problems, depending on the states in which a business operates and the extent to which it relies on government business. Sometimes our myopic approach ignores significant domestic bribery risks. The FBI has long been at the forefront of the fight against federal and state bribery in the United States. ...
OFAC is off to a fast start in 2019. It has implemented enhanced Venezuela sanctions and designated PDVSA as a Specially Designated National, and brought four separate enforcement actions with important lessons learned for sanctions compliance. In this Episode, Michael Volkov reviews OFAC’s actions and outlines important sanctions compliance lessons learned.
