Corruption, Crime & Compliance

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3 Apr, 2022

DOJ Issues Declination to Global Insurance Company Under FCPA Enforcement Policy

The Justice Department continues its enforcement “silence” with no major corporate prosecutions announced this year. It is an interesting question but it appears that the wheels have ground to a halt, with one major exception – prosecutors are bringing cases against individuals. Inside the Justice Department corporate criminal FCPA enforcement has been held up. For FCPA practitioners and commentators, that leaves individual cases and corporate...

Putin’s Puppets Pick on Peppa Pig: Intellectual property rights are collateral damage in the economic war between Russia and the nations supporting Ukraine

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31 Mar, 2022

Putin’s Puppets Pick on Peppa Pig: Intellectual property rights are collateral damage in the economic war between Russia and the nations supporting Ukraine

Jessica Sanderson, Partner at The Volkov Law Group, joins us for an interesting posting on the impact of Russia sanctions on intellectual property. Jessica can be reached at [email protected]. As we’ve reported elsewhere in our blog, the U.S., EU, and other nations recently have enacted significant economic sanctions against Russian individuals and entities in response to Russia’s invasion of Ukraine. Russia is striking back, and...

General

30 Mar, 2022

Interpreting OFAC Sanctions: The Fine Line Between Compliance and Evasion

Matt Stankiewicz, Partner at The Volkov Law Group, joins us for a posting on compliance with OFAC Sanctions. Matt can be reached at [email protected]. Unsurprisingly, we’ve been fielding a significant number of inquiries regarding the latest Russian sanctions. Most companies seek black and white answers – what can we do and what can’t we do. However, sanctions are very rarely, if ever, that black and...

Boeing Technical Pilot Acquitted on Criminal Charges from 737 Max Safety Scandal

General

29 Mar, 2022

Boeing Technical Pilot Acquitted on Criminal Charges from 737 Max Safety Scandal

The Department of Justice criminal prosecution of Mark Forkner, chief technical pilot at Boeing responsible for the 737 Max, ended in quick acquittal. DOJ prosecutors suffered an embarrassing loss in an attempt to hold Forkner responsible for misleading FAA officials on the training level required for pilots flying the 737 MAX. DOJ’s loss ends its prosecutions stemming from the Boeing 737 Max safety scandal. In...

DOJ Charges Russian Officials for Two Historical Hacking Campaigns

General

27 Mar, 2022

DOJ Charges Russian Officials for Two Historical Hacking Campaigns

The Justice Department continues to prosecute Russian-related crimes. Since the Ukraine Crisis, DOJ has steadily been announcing criminal charges against defendants connected to Russia. In its most recent action, DOJ unsealed two indictments charging four Russian nationals who were employed by the Russian government with two separate computer hacking conspiracies that targeted the global energy sector between 2012 and 2018. In sum, these hacking campaigns...

General

24 Mar, 2022

The Power of a Corporate Mission, Values-Based Leadership and the “S” of ESG

The ESG movement presents numerous opportunities for organizations to promote and improve overall performance. By injecting the important focus on “sustainability,” organizations can take a broader view of their respective corporate missions to advance numerous objectives, including the financial bottom line. Under “traditional” economic analysis (e.g. Milton Friedman and a shareholder-interests only), a corporation’s sole mission was to increase shareholder value. The market rules and...

General

23 Mar, 2022

FinCEN Settles with USAA Federal Savings Bank for $140 Million for Willful AML Violations

FinCEN enforcement actions for anti-money laundering violations are often interesting because of the scope of violations and the large penalties imposed. For most financial institutions, CCOs read these enforcement actions with an eye to distinguishing their own AML programs from the target involved in the enforcement action. I would urge some caution here – it is easy to breathe a sigh of relief and whisper...

General

22 Mar, 2022

FINRA Issues Guidance on CCO Liability

I am reluctant to wade into the issue of CCO liability because I gravitate toward a simplistic answer to a complex question – when does a CCO cross the line to warrant civil or even criminal prosecution? My simplistic response is trite – “When they break the law or when the facts warrant prosecution.” Based on my simplistic view, I have resisted dramatic warnings and...

United States Slaps Additional Sanctions on Russia Against Luxury Goods

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18 Mar, 2022

United States Slaps Additional Sanctions on Russia Against Luxury Goods

Keeping up with the Russia Sanctions and Export Controls is a challenge. Each day a new sanction or restriction is adopted with ripple actions by United States Allies and partners. Last Friday, March 11, 2022, was no exception to the shifting sanctions actions. First, the White House issued a new Executive Order 14068, and four new General Licenses. EO 14068 banned exports of a number...