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OFAC Issues Notice of Violation Against Puerto Rico Bank But Imposes No Penalty for Sanctions Violations

The Department of Treasury’s Office of Foreign Assets Control (“OFAC”) issued a finding of violation (“FoV”) to Nodus International Bank, Inc. (“Nodus”), located in Puerto Rico, for violation of Venezuelan Sanctions. Nordus voluntarily disclosed three unauthorized transactions in which a Specially Designated National (“SDN”) had an interest. Nodus failed to maintain accurate records related to the handling of blocked property.  OFAC determined that a FoV...

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Bittrex’s Sanctions and AML Violations: The Importance of Compliance Controls for the Cryptocurrency Industry (Part II of II)

Matt Stankiewicz, Partner at The Volkov Law Group, continues his discussion of recent enforcement actions by OFAC and FinCEN.  He can be reached at [email protected]. In parallel with the Office of Foreign Assets Control (“OFAC”), the Financial Crimes Enforcement Network (“FinCEN”) settled with Bittrex, Inc. (“Bittrex”), a cryptocurrency exchange that allows users to trader virtual assets, for willful violations of the Bank Secrecy Act (“BSA”)’s...

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OFAC and FinCEN Reach Settlement Agreement with Virtual Currency Exchange Bittrex (Part I of II)

Matt Stankiewicz, Partner at The Volkov Law Group, joins us for a posting on sanctions compliance in the cryptocurrency industry.  He can be reached at [email protected]. On October 11, 2022, the Office of Foreign Assets Control (“OFAC”) and the Financial Crimes Enforcement Network (“FinCEN”) announced settlement agreements with Bittrex, Inc. (“Bittrex”), a cryptocurrency exchange based in Bellevue, WA.  As part of its settlement with OFAC,...

BIS Adopts New Export Controls Aimed at Impeding China’s Ability to Acquire Advanced Computing Capabilities

Alex Cotoia, Regulatory Manager at The Volkov Law Group, rejoins us for an important posting on new Commerce Department rules relating to computer product exports to China. Alex can be reached at [email protected]. On October 13, 2022, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) published an interim final rule that significantly expanded export controls designed to thwart China’s efforts to acquire...

New Podcast Episode 250 — Cybersecurity Risks for Financial Institutions Relying on the Cloud — An Interview of Carlo Massimo

The newest episode of the re-branded Corruption Crime & Compliance has dropped!! The Episode can be accessed here. Financial institutions are rapidly moving their operations to the cloud.  In response to this development, and the increasing risks of cyber breaches, legislators and regulators are gearing up to impose significant cybersecurity requirements.   Carlo Massimo is a journalist who covers Cyber Security and International Tech Policy. Carlo...

Lessons Learned from OFAC’s Settlement with Tango Card

Alex Cotoia, Regulatory Manager at The Volkov Law Group, rejoins us for a review of OFAC’s recent settlement with Tango Card for sanctions violations. Alex can be reached at [email protected]. On September 30, 2022, the United States Department of the Treasury’s Office of Foreign Asset Control (“OFAC”) announced a settlement with Tango Card, Inc. (“Tango Card”), a supplier and distributor of stored valued cards used...

Pulling Back the Curtain on CFIUS

The global economy and geopolitical trends have elevated the importance of trade compliance status and responsibilities.  We have witnessed a dramatic increase in the complexity and risks surrounding economic sanctions and export controls. Trade compliance professionals have to navigate a rapidly changing set of regulations.  Backing these rules and regulations is the Department of Justice looking for high-profile and significant cases to prosecute. On top...

DOJ Brings Largest Pandemic Fraud Case Charging 47 Individuals with Conspiracy to Commit Fraud For Theft of $250 Million from Children’s Food Program

In the legal and compliance space, it is easy to ignore significant incidents involving domestic bribery and fraud.  We are fixated on FCPA foreign bribery cases, as well as domestic healthcare fraud, anti-kickback violations and Stark Law incidents. But when it comes to significant domestic fraud, the Justice Department has its hands full with fraud cases involving federal aid programs implemented during the COVID-19 pandemic....

Antitrust Division Sets Sights on Global Enforcement Against Digital Economy Monopolies

You have to give Antitrust Division Assistant Attorney General Jonathan Kanter credit.  He sticks to his principles, his priorities and his integrity.  AAG Kanter has launched an aggressive antitrust enforcement program with mixed results so far.  AAG Kanter understands one important thing — it takes time to turn around antitrust law and precedent to reflect new theories and underpinnings of antitrust law.  AAG Kanter has...

VMware pays SEC $8 Million for Misleading Financial Reporting

The Securities and Exchange Commission’s bread-and-butter enforcement actions focus on accounting fraud.  The SEC has a long history in uncovering fraudulent financial reporting schemes.  In the early 2000s, Wall Street was shaken by a number of scandals involving financial reporting fraud which eventually resulted in passage of the Sarbanes-Oxley Act.  This Act transformed the auditing profession and to this day is the most important reform...