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Episode 319 — Deep Dive into SCG Plastics $20 Million Settlement with OFAC to Resolve Violations of Iran Sanctions Program

Episode 319 — Deep Dive into SCG Plastics $20 Million Settlement with OFAC to Resolve Violations of Iran Sanctions Program

OFAC is capable of extending a long-arm of enforcement, reaching sometimes non-U.S. companies that may “cause” another company to violate U.S. Sanctions laws.  If you need to find an example of this long reach, look no further than OFAC’s recent settlement with SCG Plastics (“SCG”), in which SCG, a Thailand company, which sells plastic resins, agreed to pay $20 million for violations of the Iran...

DOJ Charges Ten Individuals for Violating Venezuelan Sanctions

DOJ Charges Ten Individuals for Violating Venezuelan Sanctions

On April 22, 2024, the U.S. Department of Justice announced the indictment of 10 Venezuelan individuals for conspiring to violate the International Economic Emergency Powers Act (“IEEPA”). According to the DOJ, the individuals conspired to decade U.S. sanctions imposed on Petroleos de Venezuela S.A. (“PDVSA”) in January 2019. In April 2024, one of the defendants was arrested upon arrival at Miami’s internal Airport.  The Violations...

NIST Adopts New 2.0 Cybersecurity Framework

NIST Adopts New 2.0 Cybersecurity Framework

In the absence of federal cybersecurity and data privacy laws, companies have to look to other sources of guidance, including industry standards, and state laws.  The National Institute of Standards and Technology (“NIST”) has sought to fill some of the large gaps on the issue of cybersecurity.  Enforcement agencies often cite the NIST Framework as an important barometer of an organization’s commitment to cybersecurity risks...

New BIS Rule Implementing AUKUS Effectuates Sweeping Changes to Dual Use Export Controls

New BIS Rule Implementing AUKUS Effectuates Sweeping Changes to Dual Use Export Controls

On April 19, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) published an interim final rule (“IFR”) that officially codifies certain changes to the Export Administration Regulations (“EAR”) precipitated by the United States’ participation in the Australia, United Kingdom, and United States (“AUKUS”) Trilateral Security Partnership. Announced in September 2021, AUKUS is intended to enhance the overall defense capabilities of each participating...

DOJ Heralds New Voluntary Self-Disclosure Program for Individuals

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]. On April 15, 2024 Nicole Argentieri, Principal Deputy Assistant Attorney General and the Head of the U.S. Department of Justice’s (“DOJ’s”) Criminal Division, announced a new voluntary self-disclosure program for individuals complicit in certain types of organized...

La Oficina de Control de Activos (OFAC) no renovó la licencia 44 y en consecuencia se revoca el alivio de Sanciones a Venezuela

La Oficina de Control de Activos (OFAC) no renovó la licencia 44 y en consecuencia se revoca el alivio de Sanciones a Venezuela

El 17 de abril de 2024, la OFAC revocó formalmente el alivio de sanciones que anteriormente había proporcionado a la industria petrolera y de gas en Venezuela. Mediante la licencia 44 la OFAC había proporcionado un alivio de sanciones a Venezuela en condición de que el gobierno de Venezuela organizara unas elecciones libres y justas. Debido al incumplimiento del gobierno de Venezuela, la OFAC revocó...

Episode 318 — LRN’s Recent Study Underscores Importance of Ethical Culture and Values-Based Leadership

Episode 318 — LRN’s Recent Study Underscores Importance of Ethical Culture and Values-Based Leadership

LRN continues to set the standard for ethics and compliance program research.  Volkov Law is  a supporter of, and advocate for, LRN’s research because it has consistently confirmed what we all know and believe — ethical companies perform better in the marketplace over the long run.  It is an intuitive fact that employees respond better to values-based leadership than a rules-based environment and culture.  Volkov...

OFAC Rolls Back Venezuelan Sanctions Relief, Again Prohibiting Oil and Gas Transactions

OFAC Rolls Back Venezuelan Sanctions Relief, Again Prohibiting Oil and Gas Transactions

On April 17, 2024, OFAC formally rolled back the sanctions relief it previously provided to the Venezuelan oil and gas industry.  While OFAC provided the initial relief believing that Venezuela would permit a fair and open election, it appears that the Maduro regime has fallen short of its commitments.  As such, and as part of its agreement with the beleaguered South American nation, OFAC has...

Webinar: Effective Strategies to Handle Whistleblower Complaints

Webinar: Effective Strategies to Handle Whistleblower Complaints May 21, 2024, 12 Noon EST Sign Up HERE Whistleblower reporting is a real and pervasive threat to companies. The Justice Department, the Securities and Exchange Commission and other regulatory agencies offer financial rewards to potential whistleblowers. This new incentive structure poses real risks for companies that whistleblowers may skip internal reporting and present concerns to fedferal prosecutors...

NAVEX 2024 Whistleblower Report Highlights Important Trend — More Reports are Being Made and More Are Being Substantiated

NAVEX 2024 Whistleblower Report Highlights Important Trend — More Reports are Being Made and More Are Being Substantiated

NAVEX continues to produce high-quality compliance reports, many of which are a must-read in the compliance industry.  Its annual Whistleblower Report is of particular note — NAVEX is the leading provider of hotline services in the world and its data is invaluable as a source of trends in this industry. This year –2024 — is no exception.  NAVEX combed through the data from 3784 organizations...