In the face of rapid technology changes, the Department of Justice usually has to play catch up. When cryptocurrency and blockchain entered the United States economy, the Justice Department played catch up. Fraudsters and other criminals innovate and embrace new technologies to prey on victims. The Justice Department usually catches up but there is often a lag as “innovative” criminals gain certain market advantages. DOJ...
In Part I, we discussed the basics behind the UK Modern Slavery Act of 2015. To briefly reiterate, that Act requires any company doing business in the UK with an annual turnover of £36 million or more to publicize their efforts in combatting modern slavery in their respective supply chains through an annual statement. The Act itself established minimum requirements for these statements, but there...
If you follow our blog, you’ll notice lately we’ve been writing frequently on topics related to human trafficking and modern slavery. This is no accident, as new laws and regulations related to this growing area of compliance continue to spring into existence. Lately, I’ve fielded some inquiries related to the UK Modern Slavery Act of 2015. While the Act is not necessarily new, there has...
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...
The sheer proliferation of supply chain transparency and accountability regulations at international scale itself warrants a closer look at the level of scrutiny required of organizations with complex, multi-faceted, global, and increasingly interconnected, supply chains. Legislation as varied as the German Supply Chain Act, the Uyghur Forced Labor Prevention Act, and proposed legislation for a more comprehensive due diligence framework at the European Union (“EU”)...
On February 28, 2024, President Biden issued a new Executive Order in order to better secure the private data of U.S. citizens from being exploited by foreign adversaries of the United States. By issuing his Executive Order on Preventing Access to Americans’ Bulk Sensitive Personal Data and United States Government-Related Data by Countries of Concern, President Biden has directed the U.S. Department of Justice (“DOJ”),...
On Tuesday, February 20, 2024, Michael Volkov and Alexander Cotoia participated in a virtual roundtable hosted by Diligent Institute as part of a monthly series dedicated to providing updates to those who have availed themselves of Diligent’s well-reputed certification programs for senior corporate officers and directors. As part of the roundtable, Volkov Law highlighted current topical issues, including enforcement trends and compliance-oriented mitigation strategies focusing...
Boeing continues to struggle. As troubles mount for Boeing, it is clear that it suffers from real and pervasive culture issues that have been reflected in serious safety failures, financial difficulties, regulatory violations and serious reputational damage. Boeing’s troubles permeate every part of its organization — from the board to senior executives, to its operations and its overall ethics and compliance commitment. As a result...
Webinar: Export Controls Compliance — Nuts and Bolts March 19, 2024, 12 Noon EST SIGN UP HERE The Justice Department, the Department of Commerce’s Bureau of Industry and Security (“BIS”) and the State Department’s Directorate of Defense Trade Controls (“DDTC”) have begun an aggressive civil and criminal enforcement program. DOJ’s National Security Division has announced its intention to prosecute criminal export controls cases. From the...
In this special episode of Corruption, Crime, and Compliance, Michael Volkov joins colleague and long-time friend Tom Fox as they delve into the intricacies of recent FCPA enforcement actions, shedding light on the evolving landscape of corporate compliance. From the ABB case to the SAP settlement, Michael and Tom dissect the nuances of voluntary disclosure, extensive remediation, and the shifting priorities of the Department of...
