Corruption, Crime & Compliance

Featured Articles:

7 Jan, 2019

Sanctions Enforcement and Compliance Year in Review

The Department of Treasury’s Office of Foreign Asset Control (OFAC) has steadily expanded its influence in the enforcement landscape. Global companies now face a complex regime of sanctions that require careful navigation. As the U.S. government expands its reliance on sanctions to influence foreign actors and advance foreign policy interests, global companies have to design and implement robust trade compliance programs. In recognition of this...

Podcasts

6 Jan, 2019

Episode 71 — 2019 Ethics and Compliance Predictions and Trends

In 2018, ethics and compliance professionals continued to innovate and push for compliance program enhancements. In response to growing demand, compliance industry vendors helped to implement new and innovative tools for use in compliance programs. In this episode, Michael Volkov reviews ethics and compliance trends and developments during 2018 and outlines predictions for the upcoming year.

General

3 Jan, 2019

FCPA Predictions for 2019

Here we go – another year, another set of predictions. Who knows whether they will come true? Actually, I went back and read my annual prediction posting for 2018 and 2017, respectively. Some things I called correctly, and others I missed the mark on. One consistent error – the Wal-Mart FCPA case would be resolved. So this year, I am employing reverse psychology. The Wal-Mart...

General

2 Jan, 2019

2018 FCPA Year in Review: The More Things Change, The More They Stay the Same

Happy New Year! Another year is in the books for FCPA enforcement and compliance. The headline for this past year (like many other years) is/was – The more things change, the more they stay the same. FCPA enforcement is bipartisan and immune from political winds. I may live to regret this assertion. Whether DOJ is under Republican or Democrat control, FCPA enforcement will continue. DOJ’s...

Podcasts

1 Jan, 2019

Episode 70 — FCPA Year in Review and Predictions for 2019

The Justice Department and the Securities and Exchange Commission had another strong year in FCPA enforcement. The numbers for 2018 tell a compelling story. Corporations Individuals Declinations Fines/Penalties DOJ 5 26 4 $950 million SEC 14 4 NA $380 million Total 19 30 4 $1.33 billion In this episode, Michael Volkov reviews FCPA enforcement for 2018 and outlines interesting trends and developments.

Events

31 Dec, 2018

Webinar: Review of 2018 FCPA Enforcement and Compliance Trends

Webinar: Review of 2018 FCPA Enforcement January 8, 2019, 12 Noon EST Sign up HERE In 2018, the Department of Justice and the Securities and Exchange Commission continued aggressive enforcement of the FCPA. The Justice Department’s FCPA Corporate Enforcement Policy has begun to bear fruit, and the SEC has continued its steady rate of enforcement. Interestingly, the Justice Department increased the number of criminal indictments...

General

23 Dec, 2018

Happy Holidays From The Volkov Law Group

To all of our clients, readers, subscribers, listeners, from everyone at The Volkov Law Group wishes you Happy Holidays and a Happy New Year!! We will resume our blog, podcasts and webinars with the new year — on January 2, 2019. Best wishes to all — Mike, Matt, Colleen, Stephen, Noah and Susan.

General

19 Dec, 2018

UBS Pays $15 Million for AML Compliance Deficiencies

UBS Group agreed to pay a combined $15 million penalty to the US Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”)and the SEC for regulatory deficiencies in its anti-money laundering compliance program. UBS is required to pay $5 million to the Treasury Department; $5 million to the SEC and another $5 million to FinCEN. UBS’ broker-dealer unit, UBS Financial Services, Inc. (“UBSFS”), violated the Bank Secrecy...

General

18 Dec, 2018

OFAC Announces Russia Sanctions Settlement with Software Company

The Department of Treasury’s Office of Foreign Asset Control (“OFAC”) recently announced a settlement against Cobham Holdings (and its former subsidiary Aeroflex/Metelics, Inc. (“Metelics”, a software company) for $87,507 for violations of OFAC’s Ukraine-Russia sanctions program. (OFAC announcement here). Metelics violated the Ukraine-Russia sanctions program on three occasions between July 31, 2014 and January 15, 2015, by selling telecommunications and computer software (3,400 switch limiters;...

Podcasts

16 Dec, 2018

Episode 69 — Update on DOJ Corporate Enforcement Policies

The Department of Justice (DOJ) has announced a number of modifications to its policies governing prosecution of corporations for criminal and civil violations of law. In 2017, DOJ announced its FCPA Corporate Enforcement Policy. Over the last year, DOJ expanded this policy to apply to non-FCPA corporate violations, as well as mergers and acquisitions. In addition, DOJ recently announced the adoption of an Anti-Piling On...