The Justice Department has brought three corporate FCPA enforcement actions in 2023 (if you include the Ericsson DPA breach settlement).  With its recent announcement of a declination under the Corporate Enforcement Policy, DOJ has declined two FCPA cases and one healthcare fraud case in 2023. DOJ publicizes the declination letters issued in accordance with the Corporate Enforcement Policy.  DOJ officials have made numerous public statements...

Companies have a vested interest in preserving internal communications for a variety of reasons — to hold actors accountable, and to protect the organization from potential private and government claims or investigations that may have serious direct or collateral consequences. Companies that want to use ephemeral messaging systems can do so but they have to understand the risks involved and tailor appropriate controls and procedures...

Matt Stankiewicz, Partner at The Volkov Law Group, provides a post on the latest fraud charges in the cryptocurrency industry, brought against SafeMoon. Matt can be reached at [email protected]. On November 1, 2023, the U.S. Department of Justice (“DOJ”) and U.S. Securities and Exchange Commission (“SEC”) brought charges against cryptocurrency project SafeMoon LLC and its U.S. subsidiary SafeMoon US LLC, along with its three executives,...

On January 1, 2024, the long-awaited EU Corporate Sustainability Reporting Directive (“CSRD”) begins to take effect. The CSRD is intended to redefine corporate social responsibility expectations for both in-scope companies and out-of-scope third-parties with whom they transact. This regulatory overhaul concentrates enforcement efforts on global supply chains, requiring in-scope companies to take an active role in safeguarding human rights not just within their own operations,...

The Justice Department has had a slow year in FCPA enforcement (another profound grasp of the obvious).  The reasons for this may be a question of timing elements in the pipeline of cases.  What is clear is that pushing through an enforcement action and settlement requires increased coordination with a growing number of international partners.  That may be part of the explanation. In this environment,...

From Compliance to Sustainability December 6, 2023 10 am EST/4 pm CET SIGN UP HERE Gan Integrity and Control Risks have announced an important upcoming webinar addressing the evolving third-party risk management context — From Compliance to Sustainability. Third-party risk management has evolved at a rapid pace over the past decade. The regulatory environment has quickly followed suit. Enterprises, however, are struggling to keep up...

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). Susan and Michael discuss several important findings in LRN’s 2023 Report: High-performing ethics and compliance programs rely principally on values to motivate and guide ethical and compliant behavior — LRN’s Report confirms again...

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]. Recent comments from the top leadership of both the Directorate of Defense Trade Controls (“DDTC”) and Bureau of Industry and Security (“BIS”) during a government and defense...

Matt Stankiewicz, socio en The Volkov Law Group PC, se une otra vez a nuestro blog para discutir el context del Alivio de las sanciones en Venezuela por parte del gobierno de EEUU. Matt lo pueden contactar en [email protected].  Este blog fue traducido por: Daniela Melendez, la pueden contactar en [email protected]. Como lo mencionamos en nuestro artículo la semana pasada, la Oficina de Control de...

Rewards programs have become ubiquitous in recent years. These so-called loyalty management programs exist to nudge customers or employees in a particular direction; a company’s workers might be inclined to exercise more regularly, for example, if they know there is a $5 gift card waiting for them after a specified number of gym check-ins. Their rapid expansion and cash-equivalent, pre-paid nature make loyalty management programs...