Featured Articles:

DOJ Charges Two Companies and A Dozen Individuals for Export Control and Sanctions Violations to Aid Russian Military

The Justice Department promised aggressive enforcement of export controls and sanctions against Russia.  To that end, DOJ initiated the KleptoCapture task force to focus law enforcement investigations of export violators.  DOJ and the KleptoCapture task force have delivered.  The first significant case confirms the importance of tracking DOJ and law enforcement resources.  When an initiative is announced and includes assignment of personnel, you can rest...

Antitrust Division Keeps on Pushing and Announces Initial Settlements of Potentially Illegal Interlocking Directorates

The Antitrust Division announced last year that it intended to reinvigorate enforcement of Section 8 of the Clayton Act, which prohibits directors and officers serving simultaneously on the boards of competitors (with limited exceptions). Assistant Attorney General Jonathan Kanter continues to implement his aggressive agenda unfazed by his mixed record of success in litigation. In particular, the Antitrust Division has an uneven record in its...

Lafarge and Syrian Subsidiary Pay $778 Million in Fines and Forfeiture for Supporting ISIS Terrorist Organization

The Justice Department continues to push an aggressive agenda against businesses.  It is committed to demonstrating its resolve to prosecute companies and individuals from the business community.  Whether it is antitrust, FCPA, False Claims Act, or other assorted white collar crimes, DOJ continues to demonstrate its focus on white collar crimes.  The lowest-hanging fruit to demonstrate this renewed focus is to focus on companies connected...

Episode 251 — Training and Corporate Culture: Interview of Maria D’Avanzo, Chief Evangelist Officer, Traliant

Episode 251 is available here. Maria D’Avanzo is the Chief Evangelist Officer at Traliant.  Maria provides key insights on corporate ethics and compliance training programs.  Maria describes how to take your training program to the next level and tailor the content to deliver training on important issues based on your company’s risk assessment. In this Episode, Mike and Maria discuss compliance training, culture and new...

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...