Corporate leaders often talk to the talk when it comes to a Speak Up culture. In theory, many business leaders can articulate their commitment to a Speak Up culture by emphasizing the importance of employees raising concerns. It all sounds great and is usually reflected on paper in the form of positive statements in the code of conduct and other communications. All too often, however,...
It is time to break out the crystal ball for FCPA 2020 Predictions. In preparing for this, I always rely on my past admiration of Carnac the Magnificent (see here and here for a couple of examples). There are some trends that are becoming more reliable to “predict” or just observe. DOJ is steadily adhering to the principles outlined in its FCPA Corporate Enforcement Policy. ...
In a record year, there are bound to be numerous interesting enforcement actions and principles. I picked out a few to highlight. It is surprising to say the least that DOJ continues to return large enforcement actions against a number of global companies. You would think after the last ten years of aggressive enforcement companies would refrain from bribery schemes or dedicate resources to cleaning...
Happy New Year!! In the FCPA arena, 2019 was a record year – in enforcement and compliance. Many continuing trends are becoming more than trends – meaning they are turning into established practices. Enforcement First, let’s start with the numbers. DOJ settled 7 enforcement actions and issued declinations in two cases. The seven cases involved MTS Telesystems, Fresenius, Walmart, Technip/FMC, Microsoft, Samsung and Ericsson. The...
The Justice Department and the SEC had a record year in FCPA enforcement — the largest amount of penalties against corporate defendants and the most individuals charged in one year. DOJ also adopted new guidance on corporate compliance programs. The Justice Department’s enforcement year included several major prosecutions, including Ericsson, Walmart, Fresenius Medical and Cognizant Technology. In this Episode, Michael Volkov reviews 2019 FCPA enforcement...
The Volkov Law Group is pleased to announce that Elizabeth (“Liz”) Slim has joined the firm as a Senior Consultant. Liz can be reached at Eslim@volkovlaw.com. Liz has been a Certified Anti-Money Laundering Specialist (“CAMS”) for 15 years; she has over thirty-five (35) years specializing in bank operations, compliance, risk management and regulatory training at various community to mid-size financial institutions. For the last fifteen...
2019 — The FCPA Year in Review January 7, 2020, 12 Noon EST FCPA Sign Up HERE 2019 — OFAC and Sanctions Enforcement January 21, 2020, 12 Noon EST OFAC Sign Up HERE FCPA: The Justice Department and the SEC had a record year in FCPA enforcement — the largest amount of penalties against corporate defendants and the most individuals charged in one year. DOJ also adopted...
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, 2020. Best wishes to all — Mike, Jessica, Matt, and Noah.
The Treasury Department’s Office of Foreign Asset Control (“OFAC”) continues to rack up settlements. Two travel insurance companies recently settled OFAC enforcement actions for violations of the Cuban Embargo. Allianz Global Risks Allianz Global Risks US Insurance Company (“AGR US”) is the US subsidiary of the German financial company. AGR US operates AGR Canada as a branch office in Toronto, Canada. AGR US agreed to...
Jessica Sanderson, Of Counsel at The Volkov Law Group, rejoins us for a posting on gift-giving, the holiday season and compliance messaging. Jessica can be reached at jsanderson@volkovlaw.com. As the holidays quickly approach, consider sending a message from the Board or senior management reminding employees about your gift and hospitality policy. DOJ Guidance highlights tailored communications as a “hallmark” of any well-designed compliance program, and...
