Corruption, Crime & Compliance

Featured Articles:

3 May, 2021

SAP Reaches Broad Settlement and Agrees to Pay More Than $8 Million for Violations of Iran Sanctions Program (Part I of IV)

In a precedent-setting agreement, the Justice Department, OFAC and the Bureau of Industry and Security announced a settlement with SAP SE for more than $8 million for numerous violations of the Iran Sanctions program. While the Justice Department’s National Security Division (“NSD”) has settled prior export control and sanctions cases against corporations for violations of the North Korea Sanctions program, the SAP case is the...

Podcasts

2 May, 2021

Episode 192 — The DOJ-SAP Settlement: A New Compliance Frontier

In a precedent-setting agreement, the Justice Department, OFAC and the Bureau of Industry Security announced a settlement with SAP SE for more than $8 million for numerous violations of the Iran Sanctions program. While the Justice Department’s National Security Division (“NSD”) has settled prior export control and sanctions cases against corporations for violations of the North Korea Sanctions program, the SAP case is the first...

General

30 Apr, 2021

SEC Risk Alert on ESG Investing

I have written extensively about the new and hot business trend – environmental, social and governance programs (“ESG”). The luster surrounding ESG has been a significant business trend and priority. Like any new trend, the SEC as an important protector of investor interests issued a Risk Alert for investment products and financial services that include ESG factors. Investors are demanding investment products and financial services...

General

29 Apr, 2021

ESG Automation: Picking the Right Solution

The ESG bandwagon continues to roll – investors, companies and business media are all touting the importance of ESG for corporate success. Right behind are a number of ESG vendors, who are providing automated platforms to manage ESG criteria, measurement and reporting. The new gold rush has begun and continues to gain momentum. Companies interested in ESG have to define their program, the criteria for...

General

28 Apr, 2021

Compliance Understanding of Business Processes

We often hear the adage – “compliance has to understand a company’s business;” “compliance has to work well with the business side.” While I generally agree in principle with these phrases, there is a more important point here. A compliance professional has to understand a business, the specific business processes, and its operations. In other words, a compliance officer has to understand step-by-step a business...

General

27 Apr, 2021

Alliance Steel Settles with OFAC for $435,003 for Violations of the Iran Sanctions Program

Alliance Steel, a US company based in Oklahoma, agreed to pay $435,003 to OFAC to settle violations of the Iran Sanctions Program. Alliance Steel is a designer and manufacturer of prefabricated steel structures. Alliance Steel voluntarily disclosed to OFAC 61 violations of the Iran Sanctions programs. Over a five-year period, Alliance Steel maintained a professional relationship with an Iran engineering company. The OFAV violations occurred...

General

26 Apr, 2021

Whistleblower Protections under the Anti-Money Laundering Act of 2020

Alex Cotoia, Regulatory Manager and Compliance Consultant at the Volkov Law Group, re-joins us for a posting on whistleblower protections. Alex can be reached at [email protected]. When Congress overrode former President Donald J. Trump’s veto of the 2021 National Defense Authorization Act (“NDAA”) in January of this year, it simultaneously enacted the Anti-Money Laundering Act of 2020 (“AMLA”) into law. AMLA significantly expands upon the...

Podcasts

25 Apr, 2021

Episode 191 — Interview of Chad Main, Founder of Percipient, a Leading Legal and Compliance Technology Firm

Chad Main is the Founder of Percipient, a legal and compliance technology firm. Chad joins Michael Volkov for a discussion of current legal and compliance technology trends.Chad provides helpful advice on use of technology in compliance programs and functions. Chad’s company website is Here.

General

23 Apr, 2021

Auditors, Lawyers and the Lack of “Independence” — Bias and Financial Incentives

We are surrounded by bias in a variety of contexts – news, politics, books and Internet information. Given the overwhelming amount of information, some find comfort in information supplied by sources with a bias. We have become comfortable with some level of bias. The key is to understand the bias, the lack of objectivity and then filter the information. Given the highly-charged political and...

General

22 Apr, 2021

Burma Sanctions and Export Licensing Prohibitions Implemented in Response to Military Coup

Recently, on April 9, 2021, the US Commerce Department’s Bureau of Industry and Security (BIS) adopted new restrictions targeting Burma by applying Export Administration Regulations’(EAR’s) military-intelligence end-use and end-user controls. These controls were first issued in January 2021 and became effective in March 2021. The original rule adopted in January 2021 imposed new end-use and end-user requirements, and new controls on support activities by US...