Featured Articles:

Auditors, Lawyers and the Lack of “Independence” — Bias and Financial Incentives

We are surrounded by bias in a variety of contexts –  news, politics, books and Internet information.  Given the overwhelming amount of information, some find comfort in information supplied by sources with a bias.  We have become comfortable with some level of bias.  The key is to understand the bias, the lack of objectivity and then filter the information.   Given the highly-charged political and...

Burma Sanctions and Export Licensing Prohibitions Implemented in Response to Military Coup

Recently, on April 9, 2021, the US Commerce Department’s Bureau of Industry and Security (BIS) adopted new restrictions targeting Burma by applying Export Administration Regulations’(EAR’s) military-intelligence end-use and end-user controls.  These controls were first issued in January 2021 and became effective in March 2021.  The original rule adopted in January 2021 imposed new end-use and end-user requirements, and new controls on support activities by US...

Blue Umbrella Webinar: Anti-Corruption Risks and Compliance Trends in the Pharmaceutical, Medical Device and Life Science Industries

Tuesday, May 11, 2021 1 PM EST Sign-Up HERE Pharmaceutical, medical device and life science companies continue to face escalating anti-corruption risks in the global marketplace.  Companies in these industries face a complex global maze of foreign government laws and regulations that create significant risks for global companies in these sectors. The U.S. Department of Justice, the Securities and Exchange Commission, and foreign law enforcement...

Biden Administration Ratchets Up Russia Sanctions

The Biden Administration announced new and significant trade sanctions against Russia.  The action was long expected given the Biden Administration’s criticism of Russia, and was a comprehensive response to Russia’s interference in the 2020 US election, its SolarWinds cyberattack and its ongoing occupation of Crimea and threatening addition of troops along the Ukraine border. President Biden issued a new Executive Order, No. 13848, Targeting the...

american and chinese flags and usa dollars

China’s Digital Yuan: What to Know About the First Major Central Bank Digital Currency

Matt Stankiewicz, Partner at The Volkov Law Group, rejoins us for another posting on digital currencies.  Matt can be reached at mstankiewicz@volkovlaw.com. With the rise of digital currencies, it was inevitably going to attract the attention of governments.  Not just in the regulatory sense, but also in terms of utilization.  The blockchain technology underlying these virtual assets provide certain advantages over traditional paper money, some...

Episode 190 — Catching Up on Russia and Burma Sanctions Programs

Last week, the Biden Administration announced new and significant trade sanctions against Russia. The action was long expected given the Biden Administration’s criticism of Russia, and was a comprehensive response to Russia’s interference in the 2020 US election, its SolarWinds cyberattack and its ongoing occupation of Crimea and threatening addition of troops along the Ukraine border. Over the last few months, OFAC has ratcheted up sanctions against...

Where There is No Will, There’s No Way: The Bottom Line for Chief Compliance Officers

The Road to Hell is Paved with Good Intentions – Samuel Johnson, 1775. You can draft and design the best ethics and compliance program – and then fail.  You can show every compliance professional an “effective” set of ethics and compliance controls, pristine, drafted elegantly, addressing each and every risk with the perfectly calculated impact, and your program may fail.  Why? Paper compliance programs are...

Before Moving on to ESG, Fix Your Speak Up Culture!!

Ethics and compliance has to stand strong when new trends suddenly spring up. Organizations are always ready to embrace the new-fangled shiny object – in this case ESG.  Not to be a nattering nabob of negativism (see Spiro Agnew’s comment in 1966 crafted by William Safire), but organizations have to take a deep breath and renew a review of its ethics and compliance program fundamentals. ...

Gunvor Group Former Employee Pleads Guilty to FCPA Scheme to Pay Bribes to Ecuadoran Government Officials

Raymond Kohut, a 68-year old Canadian citizen, a former employee of Swiss commodities trader, Gunvor Group, Ltd., pleaded guilty to paying $22 million in bribes to Ecuadoran government officials at state-owned oil company, PetroEcuador. Kohut pleaded guilty to one count of money laundering conspiracy before a federal judge in Brooklyn, New York, the Eastern District of New York.  Kohut agreed to forfeit $2.2 million. Gunvor...