CCOs, by definition, are careful and deliberate.  It comes with the profession.  As risk managers, CCOs are skilled in identifying, assessing and acting in a risk environment. The impact of the new CCO certification requirement, however, presents serious risks that cannot be brushed off or ignored in the face of assurances that prosecutorial discretion will protect CCOs from misguided prosecutions.  Frankly, CCOs recognize that there...

The new DOJ Certification requirements certainly raise a number of new issues and risks for senior management and chief compliance officers.  In Part I of this series, I outlined the specific language and the Plea Agreement standards imposed on companies that enter into a Plea Agreement with DOJ for FCPA violations. DOJ has reiterated its support for this new Certification requirement.  Indeed, a DOJ official...

The Department of Justice continues to respond to the compliance community’s concerns about the new certification requirement adopted as part of the Glencore FCPA enforcement action.  DOJ has adopted this new requirement to “empower” CCOs and to ensure that CCOs have a “seat at the [senior management] table.”  While these are all laudable goals, CCOs continue to question whether DOJ’s new certification requirement will undermine...

Alex Cotia, Regulatory Manager and Compliance Adviser at The Volkov Law Group, rejoins us for a post on the United Kingdom’s Russia Sanctions against social media. Alex can be reached at [email protected]. Under a statutory instrument promulgated under the Sanctions and Anti-Money Laundering Act 2018 (amending the Russia (Sanctions) (EU Exit) Regulations 2019)), the UK government recently passed sweeping new trade restrictions on the provision...

The Volkov Law Group is pleased to publish this blog article written by our summer intern Victoria Rinn, a rising junior at Cornell University. After researching the law and attending a U.S. Customs and Border Protection webinar on June 16, 2022, Victoria discusses the Uyghur Forced Labor Prevention Act, which took effect on June 21, 2022, and the impact on private companies’ supply chains. On...

The Volkov Law Group is pleased to announce our first, official summer internship program. We have welcomed a diverse group of talented, intelligent, and driven college students, who are interested in pursuing legal or compliance careers. In this blog article, our intern Abigail Schuman, a rising junior at the University of Wisconsin, discusses certain legislation aimed at combatting slave labor and human trafficking in corporate...

The Justice Department’s Antitrust Division has had a rough year in the criminal arena.  While the Antitrust Division has aggressively blocked several proposed mergers, it has lost several significant criminal cases.  The Antitrust Division lost two significant cases for price-fixing in the labor market and is now in the middle of a third criminal trial against five defendants in the chicken producing industry.  The Division...