To all our clients, family, friends and colleagues, The Volkov Law Group wishes everyone Happy Holidays and Happy New Year! Our blog, webinar and podcast services will resume on January 3, 2024. In the meantime, we wish everyone peace, gratitude. joy and love!! Mike, Matt, Alex, Sam, Daniela and Ben!!
Board Oversight of the Compliance Program The GCPG cross-references the US Sentencing Guidelines board responsibility requirements of the organization’s compliance program, and provides that the board shall “be knowledgeable about the contents and operation of the compliance and ethics programs and shall exercise reasonable oversight” of the program. The board has to specifically oversee the compliance officer and the compliance committee, and “review[] information necessary...
The health care industry has a rich history of commitment and innovation in developing effective compliance programs. Going back to the 1990s, HHS elevated compliance program requirements for healthcare companies. Many of these innovations translated into strategies that became essential to the compliance industry. For example, in the 1990s, HHS’ Inspector General (“HHS-OIG”) affirmatively pushed for separation of the legal and compliance functions, resulting in...
Matt Stankiewicz, Partner at The Volkov Law Group, provides an update on the latest OFAC action against CoinList. Matt can be reached at [email protected]. On December 13, 2023, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) announced an enforcement action against CoinList Markets LLC (“CoinList”) for violations of the Ukraine-/Russia-Related sanctions. Between April 2020 and May 2022, CoinList processed 989 transactions on behalf...
By: Daniela Melendez (Associate at The Volkov Law Group) and Alex Cotoia (Regulatory Compliance Manager) New guidance from the Biden Administration mandates that freight forwarders are responsible for complying with trade sanctions and export compliance. On December 11, 2023, the Biden Administration released a 10-page sanctions advisory (“advisory note”) detailing the critical role that freight forwarders occupy in maintaining compliant supply chains. The advisory note...
On November 21, 2023, The U.S. Department of Justice (“DOJ”) announced settlement agreements with Binance Holdings Limited (“Binance”), the world’s largest cryptocurrency exchange, and Changpeng Zhao (affectionally known as “CZ” in the cryptocurrency industry), the exchange’s founder and Chief Executive Officer (“CEO”). Under these agreements, Binance and CZ each agreed to plead guilty to a variety of offenses in order to resolve the ongoing investigations. ...
When it comes to OFAC sanctions violations, honesty is the best policy. Promptly and voluntarily disclosing violations upon their discovery can pay serious dividends. So was the case for Nasdaq, Inc., which this week settled Iran sanctions violations in what could have been a $458 million OFAC penalty, for just $4.04 million, less than 1% of the applicable statutory maximum. For those who view compliance...
Matt Stankiewicz, Partner at The Volkov Law Group, finishes his series on Binance by providing key takeaways for AML compliance programs. Matt can be reached at [email protected]. Binance’s $4.3 billion fine is one of the largest penalties the DOJ has ever obtained from a corporate defendant. Furthermore, its founder and CEO Changpeng Zhao (“CZ”) was also personally subject to a fine, amounting to $150 million. ...
Matt Stankiewicz, Partner at The Volkov Law Group, continues his series of posts breaking down Binance’s recent criminal settlement. Matt can be reached at [email protected]. Binance’s settlement with the DOJ represents one of the largest criminal corporate enforcement actions ever. A review of the facts reveals that the penalty is likely warranted, as the misconduct was driven from the very top. Binance’s founder and CEO,...
Matt Stankiewicz, Partner at The Volkov Law Group, breaks down Binance’s recent criminal settlement agreements with U.S. regulators. Matt can be reached at [email protected]. On November 21, 2023, The U.S. Department of Justice (“DOJ”) announced settlement agreements with Binance Holdings Limited (“Binance”), the world’s largest cryptocurrency exchange, and Changpeng Zhao (affectionally known as “CZ” in the cryptocurrency industry), the exchange’s founder and Chief Executive Officer...
