The Department of Justice has announced its plan to aggressively enforce the new Russia Sanctions Program.  In response to the dire humanitarian situation in the Ukraine, DOJ took two significant actions – creation of the KleptoCapture Task Force and a commitment to enforcement of the Russia sanctions and export control.  DOJ’s second statement of intent is significant.  DOJ’s record of criminal enforcement of prior sanctions...

Webinar — Russia Sanctions: Impact on Your Third Party Compliance Tuesday, March 15, 2022, 1 pm EST Sign Up HERE The Volkov Law Group is pleased to announce an upcoming webinar sponsored by NAVEX on Tuesday, March 15, 2022, at 1 pm EST (10 am PST). Michael Volkov and Jesica Sanderson from The Volkov Law Group will be conducting the webinar. The Russia-Ukraine crisis has...

In an unprecedented and sweeping set of actions, the United States in coordination with its Allies and partners has implemented a robust set of sanctions and export controls against Russia designed to cripple Russia’s economy. The unprecedented actions against Russia are intended to deter Russia from continuing its violent invasion of Ukraine and attacks against the Ukrainian people. The Department of Treasury Office of Foreign...

As announced during his State of the Union, President Biden and U.S. Allies and partners, announced additional sanctions against Russia and Belarus.  In recognition of the impact of the sanctions and export controls on the energy industry, the United States and Allies released 60 million barrels of oil from strategic reserves. The new restrictions include: Expansion of BIS Sanctions from Russia to Belarus: The United...

The Russia-Ukraine crisis has created a fast-moving compliance nightmare – sanctions and export controls around the globe are changing each day.  Some major companies are pulling out of Russia completely in response to the crisis. Others are trying to keep up with sanction requirements and adjusting specific controls each day.  Whatever approach is taken, trade compliance officers have their hands full. United States On the...

In a significant step designed to increase financial pressure on Russia in response to its invasion of Ukraine, the Department of Treasury’s Office of Foreign Asset Control (“OFAC”) issued new sanctions to prohibited United States persons from engaging the Central Bank of the Russia, the National Wealth Fund of Russia, and the Ministry of Finance.  In effect, the new sanctions freeze all Central Bank assets...

In a significant step, on Saturday, February 26, 2022, the United States and leaders of the European Commission, France, Germany, Italy, the United Kingdom, and Canada announced additional sanctions against key Russian institutions and banks. The weekend announcement indicated that the specific sanctions will be released in the next few days. The United States and Allies explained that the additional measures are designed to “ensure...

The Biden Administration announced a robust set of trade sanctions and export controls against Russia in response to the Russian invasion of Ukraine.  The Treasury Department’s Office of Foreign Asset Control (“OFAC”) and the Department of Commerce’s Bureau of Industry and Security (“BIS”) issued broad sanctions and export controls respectively, designed to impose severe economic costs on Russia.  The United States, along with its Allies,...

The SEC announced the first FCPA enforcement action in 2022. South Korean telecommunications company, KT Corporation, agreed to pay $6.3 million to settle FCPA violations. As part of the settlement, KT Corp. agreed to pay $3.5 million in civil penalties and $2.8 million in disgorgement. KT Corp. is South Korea’s largest telecommunications company.  KT Corp. violated the FCPA’s books and records and internal accounting controls provisions...

Even though the size of the KT Corp. SEC enforcement action is relatively small, the underlying misconduct provides a number of important lessons learned. Let’s look at some of the most significant lessons learned: C-Suite Misconduct: KT’s slush fund was executed by a High-Level executive at KT Corp. and was funded through inflated bonus payments made to executives.  Each executive returned the over-payment to the...