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Episode 292 — A Deep Dive into 3M’s SEC FCPA Settlement

Episode 292 — A Deep Dive into 3M’s SEC FCPA Settlement

The SEC is having a good year in prosecuting FCPA cases.  The SEC’s recent settlement with 3M Corp. for $6.5 million is its seventh corporate resolution for the year.  DOJ, which has been relatively quiet so far this year, recently resolved the Corficocolombiana case, its first for the year. 3M’s conduct centered on payments for Chinese healthcare officials employed by state-owned enterprises to attend overseas...

OFAC Imposes Modest $31,867 Penalty on Emigrant Bank for Iran Sanctions Violations, Highlighting Value of Voluntary Disclosure

OFAC Imposes Modest $31,867 Penalty on Emigrant Bank for Iran Sanctions Violations, Highlighting Value of Voluntary Disclosure

Sam Finkelstein, Associate at The Volkov Law Group, rejoins us for another post on an OFAC enforcement action. Sam can be reached at [email protected]. Emigrant Bank (“Emigrant”), a U.S.-based financial institution that bills itself as the oldest bank in New York City, is the latest sanctions violator to be swept up in OFAC’s ongoing enforcement push. On September 21, OFAC announced that Emigrant agreed to...

Reminder to file your 2023 Annual Report of Blocked Property: Due date September 30, 2023

Reminder to file your 2023 Annual Report of Blocked Property: Due date September 30, 2023

On September 22, 2023, the U.S. Department of Treasury Office of Foreign Assets Control (“OFAC”) issued its “Reminder to file your 2023 annual report of Blocked Property,” noting that entities or persons subject to the reporting requirement must submit a comprehensive report of all blocked property held as of June 30, 2023, by September 30, 2023, which is a Sunday. We are encouraging our clients...

3M Pays OFAC $9.6 Million to Resolve Egregious Iran Sanctions Violations

3M Pays OFAC $9.6 Million to Resolve Egregious Iran Sanctions Violations

Sam Finkelstein, an Associate at The Volkov Law Group, rejoins us for another posting about 3M’s recent settlement for violations of the Iran Sanctions Program. Sam can be reached at [email protected]. The past few weeks have not been kind to 3M. The company recently settled with the SEC for $6.5 million to resolve alleged FCPA violations related to its Chinese subsidiary’s dealings with Chinese state-owned...

LRN’s 2023 PEI Report: Values and Corporate Culture

LRN’s 2023 PEI Report: Values and Corporate Culture

LRN’s annual Program Effectiveness Report is chock full of important findings.  Frankly, LRN’s PEI Report is a “board worthy” report (as Donna Boehme used to say — every board member should read it). LRN’s Report notes that its large data set contains the survey results from 1,860 ethics and compliance professionals from organizations around the world.  As explained by LRN, the compliance industry continues to...

OFAC & State Department Announce New Russia Sanctions, Targeting Military-Industrial Complex

OFAC & State Department Announce New Russia Sanctions, Targeting Military-Industrial Complex

Sam Finkelstein, Associate at The Volkov Law Group, rejoins us for a new posting on OFAC’s announcement of new sanctions targeting Russia’s military-industrial complex.  Sam can be reached at [email protected]. The United States is determined to ensure that no one profits off of Russia’s war against Ukraine. To that end, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has widened the...

Episode 291 — Interview of Mary Shirley on Her New Compliance Book

Episode 291 — Interview of Mary Shirley on Her New Compliance Book

Mary Shirley, a leading voice in the legal and compliance field, has just released her new book — Living Your Best Compliance Life: 65 Hacks & Cheat Codes to Level Up Your Ethics & Compliance Program. Order Mary’s New Book Here. Mary is a well-known advocate, speaker and compliance professional. She regularly speaks at Compliance events. She is mentor to the Compliance Profession. In this Episode,...

Diligent Podcast: Alex Cotoia and Tom Fox Discuss Corporate Culture Issues

Diligent Podcast: Alex Cotoia and Tom Fox Discuss Corporate Culture Issues

Alex Cotoia, Regulatory Manager at The Volkov Law Group, joined Tom Fox for a Diligent-Sponsored Podcast on building a stronger culture of compliance. You can listen to the Podcast Here. Tom Fox conducted a special series this week on building a stronger culture of compliance through targeted and effective training sponsored by Diligent. This week, Tom visited with Yvette Hollingsworth-Clark, Viktor Culjak, Jessica Czeczuga, Michael...

Webinar: Elevating Your Sanctions and Export Controls Compliance Program

October 24, 2023 12 Noon EST Sign up HERE The Department of Justice warned global companies of a new, aggressive strategy for enforcement of trade sanctions and export controls. DOJ’s message has been reinforced by the Departments of Treasury (Office of Foreign Asset Control, or “OFAC”) as to sanctions, and the Department of Commerce (Bureau of Industry and Security, or “BIS”), as to export controls....

Do We Really Need an ISO Standard for Internal Investigations?

Do We Really Need an ISO Standard for Internal Investigations?

Call me a skeptic.  Call me cynical. I understand that the International Organization for Standardization (ISO) provides valuable standardization services and guidance.  The ISO is comprised of 169 member countries. The ISO recently issued a new standard governing internal investigations.  From my vantage point, I was a critic of ISO 37001, anti-corruption compliance,  because of its over-generalization and failure to provide more specific guidance on...