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Happy Holidays

The Volkov Law Group wishes our clients, colleagues, subscribers, readers and friends and families a wonderful, happy holiday season. We are grateful for your support and your friendship. We look forward to a New Year filled with hope, recovery, and a bright path forward. Our blog, podcasts and webinars will return after the New Year. Thank you again from all of us at The Volkov...

OFAC Collects $133k from a US Individual for Violations of Iran Sanctions Program

In May 2019, OFAC released its Framework for a Sanctions Compliance Program.  OFAC announced that it intended to increase the prosecution of individuals for sanctions violations.  OFAC has brought two cases against individuals, and last week settled its third case against an individual since its May 2019 announcement. The latest case involves prohibited transactions with Iran relating to the cement clinker business. The individual, a...

United States, European Union, United Kingdom and Canada Coordinate Further Sanctions Against Belarus

In an interesting announcement, the US, EU, UK and Canada implemented additional sanctions against Belarus.  The coordinated announcement reflected the Biden Administration’s diplomatic commitment to joint sanctions actions.  The strategy is designed to increase the impact of sanctions programs in response to President Lukashenko’s pushing of a humanitarian crisis resulting from the migrant crisis in Eastern Europe. This humanitarian crisis resulted in widespread condemnation by...

Department of Justice Does the Two-Step and Announces Criminal Conspiracy Charges Against Aerospace Executives

When the Department of Justice warns businesses and individuals, everyone needs to listen and respond accordingly.  Starting in 2016, the Justice Department’s Antitrust Division warned businesses that the Antitrust Division intended to bring criminal prosecutions for illegal agreements, price-fixing/wage-fixing, in labor markets. No one should be surprised – DOJ has been bringing criminal cases against companies, executives and human resource professionals. In the beginning of...

The United States Strategy on Countering Corruption: Digging into the Anti-Corruption Initiatives (Part III of III)

The new United States Strategy on Countering Corruption includes several important statements of interest to legal and compliance professionals.  Under the third of the five pillars, Holding Corrupt Actors Accountable, the U.S. Government specifically calls out the importance of private sector commitment to anti-corruption compliance programs “to improve the international business climate by encouraging the adoption and enforcement of anti-corruption compliance programs by U.S. and...

The Five Pillars of the New Anti-Corruption Initiative (Part II of III)

The Biden Administration’s new anti-corruption initiative is a significant commitment to the battle against global corruption. According to the Biden Administration, “[c]orruption is a cancer with the body of societies – a disease that eats at public trust and the ability of governments to deliver for their citizens. The deleterious effects of corruption impact nearly all aspects of society.” At the heart of the new...

Biden Administration Announces New Anti-Corruption Strategy (Part I of III)

The Biden Administration announced a new, comprehensive anti-corruption program, the United States Strategy on Countering Corruption. The new anti-corruption policy is the follow on to the earlier announcement elevating the global anti-corruption battle to a national security concern.  After that announcement, the Biden Administration conducted a 200-day inter-agency examination to develop a comprehensive government-wide anti-corruption initiative. The Biden Administration released the new United States Strategy...

SEC Adopts Final Rule Implementing Holding Foreign Companies Accountable Act

Alex Cotoia, Regulatory Manager and Compliance Consultant, rejoins us for a blog post of the SEC’s adoption of foreign issuer disclosure rules. Alex can be reached at [email protected]. On December 3, 2021, the U.S. Securities and Exchange Commission (“SEC”) announced the adoption of a final rule that fully implements the requirements of the Holding Foreign Companies Accountable Act (“HFCAA”) enacted by the Congress and signed...

Two-Part Webinar: 2021 FCPA and Sanctions Enforcement and Compliance Reviews

2021 FCPA Enforcement & Compliance Review January 5, 2022, 12 Noon EST Sign up HERE 2021 Sanctions Enforcement & Compliance Review January 12, 2022, 12 Noon EST Sign up HERE With the continuing impact of COVID-19 and economic disruptions, the Justice Department and the SEC continued to push FCPA enforcement. DOJ and the SEC repeated broad statements confirming continued aggressive enforcement programs. However, DOJ and SEC’s...

Episode 218 — The Biden Administration’s New Strategy on Countering Corruption

The Biden Administration announced a new, comprehensive anti-corruption initiative, the United States Strategy on Countering Corruption. The new anti-corruption initiative is the follow on to the earlier announcement elevating the global anti-corruption battle to a national security concern. After that announcement, the Biden Administration conducted a 200-day inter-agency examination to develop a comprehensive government-wide anti-corruption initiative. The 38-page plan released last week outlines steps for cracking...