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DOJ Flexes Enforcement Muscle to Target Viktor Vekselberg, a Russian Oligarch and Co-Conspirator Assisting in Evasion of Russia Sanctions

Uncategorized

28 Feb, 2023

DOJ Flexes Enforcement Muscle to Target Viktor Vekselberg, a Russian Oligarch and Co-Conspirator Assisting in Evasion of Russia Sanctions

I am sticking with my 2023 prediction – DOJ is committed to aggressive enforcement of the Russia sanctions.  Most of its efforts to date have been directed against Russian Oligarchs and significant evaders who are moving products and facilitating financial transactions that directlty or indirectly further Russia’s invasion of the Ukraine. On the one-year anniversary of Russia’s unprovoked invasion of the Ukraine, DOJ announced a...

General

27 Feb, 2023

A Window into Corporate Boards’ Views for 2023

It is fun to follow all the early year views of trends, predictions and survey results.  The beginning of the year includes lots of perspectives and analyses.  Corporate boards are at the center of these important views.  In a recent survey released by National Association of Corporate Directors, the top trends unsurprisingly referred to economic worries – inflation, a potential recession and continuing business disruptions....

Podcasts

27 Feb, 2023

Episode 263: LRN’s 2023 Ethics and Compliance Program Effectiveness Report Featuring Susan Divers

LRN continues to provide important insights and trends on the importance of ethics and compliance programs.  LRN’s annual report is an important resource and needs to be reviewed by the board, senior management and all compliance-related functions. LRN’s 2023 report emphasizes the importance of commitment, investment and promotion of corporate ethics and compliance, particularly during these difficult economic and geopolitical disturbances. LRN’s report is based...

General

23 Feb, 2023

The Volkov Law Group is Hiring: Mid-Level Associate

The Volkov Law Group is offering a great opportunity for a mid-level, experienced attorney. The Volkov Law Group is a nationally-recognized boutique law firm that offers a variety of services, including white collar criminal defense, internal investigations , and ethics and compliance services, including anti-corruption, export and sanctions compliance, anti-money laundering, due diligence and third-party risk mitigation. We offer an innovative work environment with virtual offices across...

General

22 Feb, 2023

SEC Activision Enforcement Action Underscores Breadth of Disclosure Control Liability

The SEC has been pushing the envelope on enforcement initiatives.  At the same time, the SEC is pushing new disclosure obligations like cybersecurity and climate change.  The SEC is following up on the importance of disclosure obligations and the surrounding controls.  This is a new enforcement priority because the SEC is focusing beyond financial disclosures and reporting to new areas of significant risk.  The Activision...

General

21 Feb, 2023

Fifth Circuit Court of Appeals Reverses Trial Judge’s Dismissal of Criminal FCPA Charges Against Two Venezuelan Officials

In a recent decision, the Fifth Circuit Court of Appeals handed the U.S. Justice Department a victory in reversing an “out-of-whack” trial judge’s dismissal of two separate criminal indictments that were consolidated on appeal. On occasion, it is evident that some trial judges will reach a result-oriented decision without proper regard for court precedent or the literal terms of a statute.  The Fifth Circuit’s lengthy...

General

20 Feb, 2023

DOJ Charges Two Oil and Gas Traders with FCPA Bribery Scheme Involving Petrobras

In its first enforcement action of 2023, the Justice Department charged a Connecticut man and a foreign national with FCPA bribery and money laundering charges stemming from a bribery scheme to secure contracts with Petrobras in Brazil.  Glenn Oztemel was a senior oil and gas trader at two trading companies., and Eduardo Innecco, a dual Italian and Brazilian citizen, was an oil and gas broker...

Podcasts

20 Feb, 2023

Episode 262: DOJ’s Compliance Frontier:Incentives and Disincentives

The Justice Department did not just willy-nilly announce its embrace of clawbacks and deferred payment compensation punishment as a remediation tool for companies that suffer an enforcement action and settlement.  To the contrary, DOJ has been examining this issue, even citing it in important policy spheres and enforcement actions, as an important tool in its arsenal. Both the DOJ and the SEC have been weighing...

Events

16 Feb, 2023

Webinar: Breaking Down and Managing Your Third-Party Risks

March 14, 2023 12 Noon EST SIGN UP HERE In the ever-changing global economy, and in the aftermath of the pandemic and Russia’s invasion of the Ukraine, third-party risks continue to present significant risks and challenges. At the same time, global companies face escalating enforcement risks from the United States and foreign law enforcement. It is more important than ever for companies to embed third-party...

General

16 Feb, 2023

Food Company Pleads Guilty and Agrees to Pay $19.2 Million for Manufacturing Under Unsanitary Conditions

The Justice Department has a long-record of criminal prosecutions of companies for manufacturing food products under unsanitary conditions.  In recent years, DOJ has prosecuted Blue Bell Ice Cream, Chipotle, ConAgra Grocery, Peanut Corporation of America and egg producers for production of food products that resulted in serious food borne illnesses. In a recent case, Kerry, Inc., a manufacturer of breakfast cereal for Kellogg’s Honey Smacks...

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