News recently published by multiple media outlets suggest that certain subcomponents incorporated into a variety of Volkswagen-owned vehicles—including cars manufactured by luxe brands Porsche, Bentley and Audi—were sourced from an unspecified region in “western China” (“PRC”) presumed to be the Xinjiang Uyghur Autonomous Region (“XUAR”). According to these sources, Volkswagen itself was not aware of the origin of the part, which, according to the Financial...

If companies operated with perfect governance mechanisms and controls, they would all be ready for the coming sanctions enforcement storm.  However, that is not the corporate reality.  Even after several companies are the subjects of these aggressive enforcement actions, corporate boards, senior risk managers and senior executives will turn to the chief compliance officer and ask — “do we have an effective sanctions compliance program?”...

There are some things you learn best in calm, and some in storm.  Willa Cather I know I sound like a broken record.  The Justice Department’s white collar criminal enforcement  has been trending down over the last few years.  The reasons for that are unclear — is it resources, difficulty and length of investigations or just lack of initiative?  Whatever the cause may be, one...

On February 1, 2024, President Joseph R. Biden, Jr. promulgated Executive Order 14115 (“E.O. 14115), the effect of which is to impose economic sanctions on individuals ostensibly contributing to gratuitous violence and political unrest in the West Bank. Finding that the “situation in the West Bank” involved unacceptably “high levels of extremist settler violence, forced displacement of people and villages, and property destruction,” the President...

Por: Matt Stankiewicz socio en Volkov Law Group ([email protected]) y Daniela Melendez asociada en Volkov Law Group ([email protected]) El 18 de octubre de 2023, la Oficina de Control de Activos Extranjeros (“OFAC”) del Departamento del Tesoro de los Estados Unidos tomó varias medidas para proporcionarle a Venezuela un alivio limitado a las sanciones económicas impuestas. El alivio incluyó Licencias Generales que autorizaban transacciones y negocios...

Matt Stankiewicz, Partner, and Daniela Melendez, Associate, provide key updates on the Venezuela Sanctions Program. Matt can be reached at [email protected] and Daniela can be reached at [email protected]. Easy come, easy go.  On January 29, 2024, OFAC published General License 43A under the Venezuela Sanctions Regulations, which partially rolled back a piece of the sanctions relief it provided to the country only a few months prior. ...

By: Alex Cotoia, Regulatory Compliance Manager at the Volkov Law Group ([email protected]) and Daniela Melendez, Associate at the Volkov Law Group ([email protected]) Wabtec Corporation (“Wabtec”)—a global manufacturer and supplier of rail technology headquartered in Pittsburgh, Pennsylvania—recently settled an administrative enforcement proceeding with the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) involving forty-three (43) apparent violations of the antiboycott provisions of the Export...