The Justice Department’s FCPA enforcement record for 2024 was slow.  This  trend was unexpected, contrary to my own predictions and of various other prognosticators.  It is hard to explain why this slowdown occurred. DOJ’s record is hard to square against DOJ official speeches, statements and policy changes, which all were premised on an expectation of increased enforcement over prior years.  In its last FCPA enforcement...

FCPA trends often are relatively easy to describe and often overblown as a marketing technique by the usual cast of paparazzi suspects.  (Self-proclaimed prognosticators that often push incorrect themes to promote business, or those that restate profound grasps of the obvious).  2023 has been a strange year in a number of respects — socially, politically and even in the small universe of DOJ enforcement and...

This article was jointly authored by Alexander J. Cotoia, Regulatory Compliance Manager at The Volkov Law Group, and Daniela Melendez, Associate at The Volkov Law Group. Alexander and Daniela may be reached at their respective email addresses of [email protected] and [email protected]. On December 14, 2023, Congress passed the Foreign Extortion Prevention Act (“FEPA”) in an effort to address certain deficiencies inherent in the current iteration...

Alexander J. Cotoia currently serves as the Regulatory Compliance Manager at The Volkov Law Group, where he regularly advises the firm and its clients on the latest developments implicating trade compliance concerns. He may be reached at [email protected]. On December 22, 2023, President Joseph R. Biden, Jr. issued an executive order—”Taking Additional Steps With Respect to the Russian Federation’s Harmful Activities”—that subjects certain foreign financial institutions...

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has renewed its commitment to squeezing Russia’s oil proceeds, releasing updated guidance with enhanced attestation and record-keeping requirements for maritime shipping operators and other industries that participate in the transport of Russian oil. OFAC also announced sanctions against several firms operating in apparent violation of the Price Cap. The Price Cap Policy is...