Featured Articles:

DOJ’s New Corporate Compliance Guidance: Risk Assessments and Policies and Procedures (Part II of V)

The Volkov Law Group has scheduled a free webinar on DOJ’s New Compliance Program Guidance for May 9, 2019, at 12 noon EST. Sign up HERE. The Justice Department’s new Corporate Compliance Guidance is keyed to three topics:  Design of a Corporate Compliance Program  Effective Implementation  Does the Compliance Program “Work in Practice”? Part 1 of the Corporate Compliance Guidance addresses the following elements of...

Webinar: DOJ Issues New Guidance on Evaluation of Corporate Compliance Programs

DOJ Issues New Guidance on Evaluation of Corporate Compliance Programs Thursday, May 9, 2019, 12 Noon EST Sign up HERE In a major development in ethics and compliance program expectations, the Justice Department has issued a new and important revised guidance on the Evaluation of Corporate Compliance Programs.  The Justice Department has advanced the ball with respect to ethics and compliance or raised the bar...

DOJ Issues New and More Robust Guidance on Evaluation of Corporate Compliance Programs (Part I of V)

The Volkov Law Group has scheduled a free webinar on DOJ’s New Compliance Program Guidance for May 9, 2019, at 12 noon EST. Sign up HERE. In a major development in ethics and compliance program expectations, the Justice Department has issued a new and important revised guidance on the Evaluation of Corporate Compliance Programs (HERE).  The new Evaluation Guidance supersedes the prior document issued in...

OFAC Enforcement Action Underscores Russia Sectoral Sanctions

The Treasury Department’s Office of Foreign Asset Control (OFAC”) continues its enforcement run.  In a recent case against Haverly Systems, Inc., OFAC sent an important reminder to US companies about compliance with the Ukraine-Russia Sectoral Sanctions Program.  Haverly paid roughly $75,000 for two violations of the Ukraine-Russia Sectoral Sanctions (SSI).  In two transactions, Haverly violated Directive 2 of the Ukraine-Russia the 90-day maturation limitation on...

The Important Link Between Anti-Corruption Compliance and Effective Training Programs

Julie DiMauro, Regulatory Intelligence Expert, Thomson Reuters, and Michael Volkov, CEO, The Volkov Law Group We were honored to jointly present a Thomson Reuters-sponsored webinar focused on Top Anti-Corruption Compliance Risks recently; if you missed it, please find the replay here.  Global anti-corruption risks are increasing at the same time that global cooperation among prosecutors and law enforcement agencies are facilitating the detection and penalization...

Episode 87 — Review of Recent Compliance Benchmarking, Surveys and Studies

With the growth of the compliance profession and the importance of compliance functions as part of corporate governance, there has been a significant increase in the quantity and quality of compliance studies and surveys. It takes time to keep up with all the compliance information being developed and released. In this episode, Michael Volkov reviews two recent compliance studies. 

Join Us for a May 16, 2019 BVD Webinar: “Is “Power and Control” the New Beneficial Ownership?

What are the new best practices for third-party risk management? Join Michael Volkov, CEO of The Volkov Law Group; Bill Hauserman, Senior Director, Compliance Solutions, Bureau van Dijk, a Moody’s Analytics Company; and Ted Datta, Director, Governance, Risk and Compliance Solutions, Bureau van Dijk, for a live webinar on Thursday May 16, 2019, at 11 am EST/4 pm BST. Please sign up HERE.  New anti-corruption...

DOJ and OFAC Announce Another Sanctions Settlement – UniCredit Group Banks Pay Over $1.3 Billion and Subsidiary Bank Agrees to Plead Guilty for Violating Iran Sanctions

The Justice Department and the Treasury Department’s Office of Foreign Asset Control (OFAC) are on a roll.  Global banks are facing renewed prosecutions, along with aggressive sanctions prosecutions of companies for integrating acquisitions and supply chain missteps. In the latest billion-dollar plus settlement, UniCredit Bank S.p.A UC Group), based in Milan, Italy and two subsidiaries, UniCredit Bank AG (UCB AG), a German bank (aka HypoVereinsbank),...

Acteon Pays $441,000 to Settle Two OFAC Enforcement Actions

We can add Acteon to the list of OFAC settlements for 2019, which is quickly turning into a robust sanctions’ enforcement year.  Acteon is a UK based company, which provides subsea services in the oil and gas industry.  (Acteon recently announced the acquisition of Benthic, an Australian owned subsea company, which operates out of Houston, Texas). In the first enforcement action, Acteon and its operating...

The Long Arm of OFAC: Secondary Sanctions, Facilitation, and Causing a Violation

Matt Stankiewicz, Senior Associate at The Volkov Law Group, rejoins us for a blog posting on OFAC sanctions law. Matt can be contacted at mstankiewicz@volkovlaw.com. Sanctions law can be complex.  The sanctions programs themselves are often a tangled web of do’s and don’t’s – various wind down periods, General Licenses, payment structures, and more.  In order to enforce these laws and regulations, OFAC must necessarily...