Corruption, Crime & Compliance

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5 Dec, 2024

Start the New Year with Two Important Webinars: 2024 FCPA Review (Jan. 7) & 2024 Sanctions Review (Jan. 14)

2024 FCPA Year in Review January 7, 2024, 12 Noon EST SIGN UP HERE FCPA: For the Justice Department and the SEC, 2024 was an interesting year in FCPA enforcement and compliance. With the new Trump Administration taking over in 2025, DOJ’s commitment to FCPA enforcement may be questioned. This past year included several significant FCPA enforcement matters — Raytheon, Trafigura, Gunvor and SAP, along with...

General

4 Dec, 2024

OFAC Fines U.S. Person $1 Million for Multiple Violations of Sanctions Regime Against Iran

In one of the more notable enforcement actions of 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) recently imposed a $1,104,408 civil penalty on a U.S. person for 75 separate violations of the Iranian Transactions and Sanctions Regulations (“ITSR”). The underlying violations, which occurred from 2019 to 2022, involved the purchase, renovation, and operation of a hotel on the Caspian...

American Life Insurance Company Settles with OFAC for $178,421 Related to Apparent Violations of Iranian Transactions and Sanctions Regulations

Uncategorized

3 Dec, 2024

American Life Insurance Company Settles with OFAC for $178,421 Related to Apparent Violations of Iranian Transactions and Sanctions Regulations

By: Daniela Melendez, Associate at The Volkov Law Group, and Alex Cotoia, Regulatory Compliance Manager. Daniela can be reached at [email protected] and Alex can be reached out at [email protected]. The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) recently settled with American Life Insurance Company (“ALICO”), a Delaware-based subsidiary of MetLife, Inc., for $178,421, addressing apparent violations of the Iranian Transactions and Sanctions Regulations (“ITSR”)....

Antitrust Division AAG Outlines Need for More Aggressive Antitrust Enforcement in the Healthcare Industry

General

2 Dec, 2024

Antitrust Division AAG Outlines Need for More Aggressive Antitrust Enforcement in the Healthcare Industry

In an interesting political twist, the difference in approaches to antitrust enforcement between Democrat and Republican Administrations has been narrowing. It used to be that the difference in party control of the Antitrust Division and the Federal Trade Commission would have a significant impact on enforcement priorities. That gap is definitely changing and reflects growing agreement in the public in preventing anti-competitive conduct. Much of...

Episode 347 — LRN’s Code of Conduct Report

Podcasts

1 Dec, 2024

Episode 347 — LRN’s Code of Conduct Report

LRN consistently provides high-quality reports and important insights on ethics and compliance trends. Each year, LRN’s Program Effectiveness Report is anticipated as an important source of cutting-edge ethics and compliance initiatives. LRN’s Code of Conduct Report includes a number of important benchmarks for companies to use as a measure of their compliance programs. In its most recent report, LRN cites a number of important findings...

General

27 Nov, 2024

Happy Thanksgiving!

Happy Thanksgiving to our clients, friends, colleagues, and family!! We hope you have a wonderful and restful holiday. With peace and gratitude, The Volkov Law Group PC

The Continuing Importance of Conflict of Interest Compliance

General

26 Nov, 2024

The Continuing Importance of Conflict of Interest Compliance

We continue to hear about the impact of apparent or real conflicts of interest — whether in government, in business, or in other organizations. It is an issue of significant importance. Within an organization, a perceived or real conflict of interest can undermine the very integrity of the organization and a specific person’s ability to act in a manner consistent with the organization’s interests. Scandals...

Measuring Compliance Program Performance and Effectiveness

General

25 Nov, 2024

Measuring Compliance Program Performance and Effectiveness

“Only when the tide goes out do you discover who’s been swimming naked.” — Warren Buffett You often hear chief compliance officers speak about benchmarking. CCOs often reveal their competitive streaks when they collect information about other companies’ compliance programs. It can easily come off as a little insecure. In fact, CCOs are seeking valuable information — trying to measure their company’s performance outside their...

Episode 346: Forecasting the 2nd Trump Administration Enforcement and Compliance Impact

Podcasts

24 Nov, 2024

Episode 346: Forecasting the 2nd Trump Administration Enforcement and Compliance Impact

As the dust settles on the U.S. Election, companies are quickly analyzing the implications for the economy, business environment, new enforcement priorities and compliance implications. When new Administrations come into power, change is inevitable. Given the change with President Trump’s return to the White House, and in light of several of his stated intentions, companies should prepare for this new environment. The Trump Administration’s priorities...

Lessons Learned from the Telefónica FCPA Settlement (Part III of III)

General

21 Nov, 2024

Lessons Learned from the Telefónica FCPA Settlement (Part III of III)

The Justice Department’s record of FCPA enforcement in 2024 has been disappointing. With all of the hoopla and pronouncements surrounding the global war against corruption, DOJ suggested that enforcement in 2023 and 2024 would be robust. Instead, 2024 was a year of fizzles, fits and starts, and ultimately a slow year of FCPA enforcement. The future under the Trump Administration will be interesting. Based on...