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Episode 229 — DOJ Charges TV Producer with Violating Crimea-Related Sanctions

In another indication of DOJ’s aggressive approach to enforcement of sanctions against Russia, DOJ announced the indictment of a TV producer for violations of the Crimea-Related Russian sanctions program. As outlined in the indictment, Jack Hanick, a former Fox News executive, was indicted for a sanctions violations stemming from his long-time relationship with a prohibited Russian oligarch (Specially Designated National) relating to the creation and...

United States Slaps Additional Sanctions on Russia Against Luxury Goods 

Keeping up with the Russia Sanctions and Export Controls is a challenge.  Each day a new sanction or restriction is adopted with ripple actions by United States Allies and partners. Last Friday, March 11, 2022, was no exception to the shifting sanctions actions. First, the White House issued a new Executive Order 14068, and four new General Licenses.  EO 14068 banned exports of a number...

DOJ Charges United States/Russian National with Acting as an Illegal Agent under FARA

In another action targeting Russian actors and connections, the Justice Department indicted Elena Branson, a dual United States-Russian national with criminal evasion of Foreign Agents Registration Act (“FARA”) registration requirements while working on behalf of high-level Russian officials.  Specifically, Branson assisted high-level Russian officials by coordinating meetings for Russian officials to lobby United States political officials and business persons, and by operating organizations to promote...

How to Avoid Sanctions Liability Following a Ransomware Attack

Matt Stankiewicz, Partner at The Volkov Law Group, joins us for an interesting post on ransomware and OFAC sanctions compliance. Matt can be reached at [email protected] Ransomware attacks are on the rise and companies everywhere should be taking action to strengthen their cybersecurity defenses and resiliency to ensure their internal systems are able to withstand cybercrime attacks.  Cybercriminals are exceedingly sophisticated, some groups even maintain...

Compliance by Fear: An “Old” Mindset

Compliance and ethical culture mandates have experienced a significant transformation.  From the early days of compliance, organizations pigeon-holed compliance into a role akin to “law enforcement.” I will always recall meeting with a client years ago and when the CCO walked into the room, a senior executive exclaimed, “Uh, oh, the sheriff is in town.” That was not a good sign. Compliance by fear is...

Episode 228 — Update on Russia Sanctions and Export Controls

The continuing crisis in Ukraine has resulted in additional sanctions and export controls. It is hard to keep up with new developments each day. In recent steps, the United States has adopted a comprehensive set of export controls and implemented a ban on import of Russian oil, gas and coal. In this Episode, Michael Volkov reviews the recent changes to the Russia sanctions and export...

DOJ Continues Pace of Healthcare Fraud False Claims Act Prosecutions

False Claims Act prosecutions continue against healthcare executives, physicians and professionals.  Last year, DOJ recovered over $5.6 billion in FCA enforcement. DOJ expects total recoveries to increase in 2022.  Over 95 percent of False Claims Act prosecutions involved healthcare fraud and kickbacks.  Two Doctors and Eight Others Indicted for Healthcare Kickbacks In a recent prosecution in the Northern District of Texas, DOJ announced the indictment...

The Force Multiplier: Ethics and Sustainability

The rise of ESG programs did not just come out of thin air.  Frankly, in many respects, ESG tied together important trends relating to sustainability, social justice, reputational damage and climate change.  Many organizations involved in the extractive industries already had elevated sustainability as an important priority.  Indeed, for years, a number of these organizations issued annual sustainability reports. With increasing focus on environmental and...

United States and United Kingdom Move to Prohibit Russian Oil and Gas Imports

In a much-anticipated action, President Biden announced a prohibition on all Russian oil and gas imports. The United States relies on Russia oil for approximately 8 percent of its needs. Simultaneously, the United Kingdom announced it will reduce oil and gas imports from Russia over the next nine months.  The UK relies on Russian oil and gas imports for approximately 18 percent of its energy...

DOJ Charges Television Producer for Violating Crimea-Related Sanctions Program

The U.S. Attorney’s Office for the Southern Direct of New York recently announced the indictment of Jack Hanick, a United States citizen, of violating the U.S. sanctions against Russia and false statements in connection with his work for a sanctioned oligarch Konstantin Malofeyev. Hanick is a television producer ad worked with Malofeyev, a Specially Designated National (“SDN”) designated under the Crimea Sanctions Program adopted in...