The Justice Department and the Securities and Exchange Commission bounced back in 2022 to restore their records for aggressive FCPA enforcement. At the same time, DOJ announced significant new compliance program expectations, and appeared ready to press forward with a number of FCPA resolutions. The Numbers For the year, DOJ totaled five corporate resolutions, two separate declinations under its Corporate Enforcement Policy, and approximately 24...
The FTX scandal has sent (and is continuing to send) shockwaves through the cryptocurrency industry. FTX was one of the largest crypto exchanges in the world, and its CEO, Sam Bankman-Fried (SBF) was the darling of Silicon Valley and Wall Street. SBF touted FTX for its rapid growth as a crypto exchange and its deep connections to politicians, athletes and movie stars. It turned out...
Danske Bank, the largest bank in Denmark, agreed to plead guilty to fraud and paid $2 billion to settle long-standing anti-money laundering and fraud violations stemming from its banking operations in Estonia. Danske Bank plead guilty to one count of bank fraud conspiracy. The notorious Danske Bank case in Estonia has been the subject of regulators in Denmark, the European Union and non-governmental watchdogs because...
The Honeywell FCPA settlement underscored a number of important issues – lessons learned for compliance professionals. Every FCPA case carries important lessons learned, but some more than others. The Honeywell case with its focus on the large project in Brazil, and the contractual dispute in Algeria both provide important pointers relating to third party risk management. In addition to the third party issues, however, Honeywell...
The facts surrounding Honeywell’s bribery schemes in Brazil and Algeria are fairly straightforward. In Brazil, the facts underscore the significant risks of bribery when companies participate in large, valuable project competitions. Global companies face significant risks when competing and seek every advantage to win a project competition. Brazil In 2008 and 2009, Petrobras developed the Premium Refinery project to design and construct two grassroots refineries...
The Justice Department and the Securities and Exchange Commission had a strong FCPA enforcement year. However, there is certainly more to come and it is easy to predict that 2023 will be even a bigger year. It is fairly obvious that DOJ and the SEC have cases in the pipeline and with new policies in place, they are getting ready to move them through the...
Jessica Sanderson, a Partner at The Volkov Law Group, rejoins us for an important posting on the importance of compliance with defense trade controls. Jessica can be reached at [email protected]. On December 5, 2022, the Department of State, Directorate of Defense Trade Controls (“DDTC”) issued new Compliance Program Guidelines, “intended to provide an overview of an effective compliance program and an introduction to defense trade...
From all of us at the Volkov Law Group, we wanted to wish our clients, families, friends, and colleagues a wonderful holiday season and a terrific New Year!! We are so grateful for opportunities to work together, collaborate, and learn from each other. We hope that everyone is able to enjoy some time with their families, loved ones and friends during the holidays. We will...
Matt Stankiewicz, Partner at The Volkov Law Group, wraps up his blog series on FTX, highlighting some of the more interesting facts from the company’s recent bankruptcy filing. He can be reached at [email protected]. On top of all the legal trouble for FTX’s founder and CEO, Sam Bankman-Fried (“SBF”), the company has also filed for bankruptcy and SBF has been ousted as CEO. John J. Ray...
Matt Stankiewicz, Partner at The Volkov Law Group, continues his blog series on FTX, discussing the civil charges filed by the SEC and the CFTC. He can be reached at [email protected]. In conjunction with the DOJ’s criminal indictment, the SEC brought civil charges against SBF. The SEC charged SBF with orchestrating a scheme to defraud equity investors in the FTX exchange (FTX Trading Ltd.). The SEC...
