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...

In November 2023, HHS-OIG issued a comprehensive document, the General Compliance Program Guidance (“GCPG”), which outlines important compliance guidance for the healthcare industry. The GCPG provides specific guidance on compliance with the Federal anti-kickback statute (“AKS”), the Physician Self-Referral Law (“Stark Law”), the False Claims Act, HIPAA Privacy and Security, Exclusion Authorities, and Criminal Healthcare Fraud. Aside from this important compendium of statutory and regulatory...

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...

Join Diligent and The Volkov Law Group for a webinar on January 16, 2024 that explores the complexities of modern slavery and human rights compliance within the realm of third-party risk management. As organizations face heightened scrutiny and increasing expectations to uphold ethical standards, understanding and navigating the evolving legal landscape is paramount. Alexander Cotoia, Regulatory Compliance Manager at The Volkov Law Group will guide...

Within the specific element discussions in HHS-OIG’s Guidance, are important operational details and strategies for an effective compliance program.  GCPG provides important suggestions and innovations for consideration by all compliance professionals. Effective Lines of Communication The GCPG stresses the importance of an open line of communication between the compliance officer and entity personnel as a means to reduce potential fraud, waste and abuse.  To this...

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...