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C.H. Robinsom Settles with OFAC for $257,690 to Resolve Iran and Cuba Sanctions Violations

C.H. Robinsom Settles with OFAC for $257,690 to Resolve Iran and Cuba Sanctions Violations

C.H. Robinson International Inc. (CHR), a Minnesota-based global transportation and logistics company, has agreed to pay $257,690 to settle civil liability for 82 apparent violations of sanctions against Iran and Cuba conducted by five of its non-U.S. subsidiaries. Over a period of more than three years, these five subsidiaries provided freight brokerage or transportation services for 82 shipments, to or from Iran, of Iranian- or...

Episode 351 — Deep Dive in AAR Services FCPA Settlement

Episode 351 — Deep Dive in AAR Services FCPA Settlement

How did a high-stakes bribery scheme involving insider deals, Airbus planes, and secret payments bring down a global aviation giant? In this episode, Michael Volkov dives deep into the AAR Corporation FCPA case—a cautionary tale of bribery, insider deals, and compliance failures in high-risk sectors. The DOJ and the Securities and Exchange Commission (SEC) closed 2024 with a major coordinated settlement with AAR Corporation, a...

BIS Reaches $180,000 Mitigated Settlement with Indium Corporation Over Illegal Exports to Russia

BIS Reaches $180,000 Mitigated Settlement with Indium Corporation Over Illegal Exports to Russia

The U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) recently issued a Final Order against The Indium Corporation of America, citing eleven (11) alleged violations of the Export Administration Regulations (“EAR”) between April 14, 2022, and March 31, 2023. The violations involved unauthorized exports of solder preforms, solder wires, and solder ribbons to Russia. These items, though classified as EAR99, required an export...

OFAC Closes Out Year with String of Enforcement Actions — Aiotec Pays OFAC $14.55 Million to Resolve Iran Sanctions Violations

OFAC Closes Out Year with String of Enforcement Actions — Aiotec Pays OFAC $14.55 Million to Resolve Iran Sanctions Violations

Despite a relatively slow year in OFAC sanctions enforcement, OFAC closed 2024 with a string of settlements in five cases, including its second in 2024 against an individual defendant.  While OFAC had a slow year, DOJ continued to increase its criminal enforcement of sanctions cases against individuals, increasing its prosecutions to 70 in 2024, nearly 30 more than 2023 (42). However, in 2024, DOJ did...

AAR’s Bribery Schemes: Bribery in the Aviation Industry  (Part II of II)

AAR’s Bribery Schemes: Bribery in the Aviation Industry (Part II of II)

AAR, a provider of aviation products and services, engaged in two separate bribery schemes.  State-owned entities and government agencies permeate the aviation industry.  As a result, FCPA risks are embedded in direct industry activity and related services and suppliers.  The AAR case is a perfect example of just how easy it is to engage in bribery in the aviation industry. AAR engaged in two separate...

DOJ and SEC Close 2024 with FCPA Enforcement Action Against AAR Corp; DOJ and SEC Announces Resolution with Deepak Sharma, CEO of AAR Subsidiary (Part I of II)

DOJ and SEC Close 2024 with FCPA Enforcement Action Against AAR Corp; DOJ and SEC Announces Resolution with Deepak Sharma, CEO of AAR Subsidiary (Part I of II)

The Justice Department and the SEC  finished 2024 with a coordinated resolution of criminal and civil FCPA charges against AAR Corporation, an Illinois-based provider of aviation products and services.  In addition, DOJ unsealed a criminal indictment and guilty plea dated August 1, 2024, by Deepak Sharma, CEO of an AAR Subsidiary for his role in the FCPA scheme. Also, the SEC entered into a separate civil...

OFAC Designates Gazprombank for Inclusion on SDN List 

OFAC Designates Gazprombank for Inclusion on SDN List 

By: Daniela Melendez, Associate at The Volkov Law Group, and Alex Cotoia, Regulatory Compliance Manager. Daniela can be reached at [email protected] and Alex can be reached out at [email protected]. In a significant development underscoring the U.S. government’s continued efforts to counter Russia’s destabilizing activities, the U.S. Department of the Treasury recently announced the designation of Gazprombank as a Specially Designated National (“SDN”) under Executive Order 14024. This action,...

Episode 350 — Deep Dive into McKinsey FCPA Settlement

Episode 350 — Deep Dive into McKinsey FCPA Settlement

What went wrong when McKinsey paid bribes to secure consulting contracts with South Africa’s state-owned enterprises? In this episode, Michael Volkov dives into the December 2024 DOJ settlement with McKinsey & Company, which paid $122 million after being found guilty of paying bribes to officials at Transnet and Eskom to secure valuable consulting contracts. The case involved significant violations of the Foreign Corrupt Practices Act...

Happy Holidays and Happy New Year!

Happy Holidays and Happy New Year!

Happy holidays to all our clients, colleagues, family and friends. Our blog, podcasts and webinars will be back on January 6, 2025. We appreciate all the support and look forward to a great year in 2025.

DOJ Indicts Indian Billionaire and Seven Other Individuals for Bribery and Fraud Scheme Involving Payments to Indian Government Officials to Obtain Solar Energy Contracts

DOJ Indicts Indian Billionaire and Seven Other Individuals for Bribery and Fraud Scheme Involving Payments to Indian Government Officials to Obtain Solar Energy Contracts

In a far-reaching criminal case, in November 2024, the Justice Department unsealed a complex, five-count indictment in the Eastern District of New York charging eight defendants, including Gautam S. Adani, Sagar R. Adani and Vneet S. Jaain, executives of the Adani Group, a large Indian renewable-energy company, with conspiracies to commit securities and wire fraud and substantive securities fraud for their roles in a multi-billion-dollar...