Featured Articles:

2020 Year in Review: Interesting Enforcement Actions (Part III of IV)

DOJ and the SEC each had a great year in FCPA enforcement.  But it is important to acknowledge that the blockbuster case, Goldman Sachs, was the driver of this successful year.  Goldman Sachs Goldman Sachs paid DOJ and the SEC nearly $4 billion in fines and disgorgement.  DOJ has reccivered nearly $1` billion in assets through its forfeiture initiative. Goldman Sachs was a massive and...

Rescheduled Webinar: 2020 FCPA Enforcement and Compliance Review

2020 FCPA Enforcement and Compliance Trends January 12, 2021, 12 Noon EST Sign Up HERE FCPA enforcement in 2020 was a record year. The Justice Department collected a record-setting amount of criminal fines for anti-corruption violations, while continuing its aggressive criminal indictment of individuals for FCPA and other criminal offenses. In this webinar, Michael Volkov reviews FCPA enforcement and compliance issues for 2020.

2020 Year in Review: DOJ and SEC Compliance Guidance (Part II of IV)

DOJ and the SEC have provided unprecedented compliance guidance and information.  DOJ has established itself as the preeminent leader in advancing ethics and compliance programs, best practices and innovations.  No agency or global organization has had such a dramatic impact on the improvement of corporate compliance programs. To be sure, DOJ and the SEC have a two-prong strategy – first and most important, DOJ and...

2020 FCPA Review: Another Record Year for Enforcement (Part I of IV)

The Justice Department and the Securities and Exchange Commission had another record year of enforcement.  In fact, the last four years of FCPA enforcement included two years of record enforcement – 2019 and 2020.  After those two years, 2016, 2014, 2010 were larger enforcement years (as measured by total fines) than 2017 and 2018, the first two years of FCPA enforcement under the Trump Administration....

Happy Holidays!

The Volkov Law Group wishes our clients, colleagues, subscribers, readers and friends and families a wonder, happy holiday season. We are grateful for your support and your friendship. While this has been a very difficult year, we look forward to a New Year filled with hope, recovery, and a bright path forward. Our blog will return after the New Year. Thank you again from all...

Episode 175 — A Deep Dive into the Vitol FCPA Settlement

The Justice Department continues to produce FCPA resolutions in a record year for enforcement.  The latest is DOJ’s settlement with Vitol, Inc. (Vitol), an energy trading company. DOJ agreed to a three-year deferred prosecution agreement (DPA) in exchange for a criminal penalty of $135 million.  One-third of the payment, or $45 million, would be credited if Vitol pays $45 million to Brazil prosecutors for resolution of the case....

Episode 174: Five Basic Steps to Implement a Sanctions Compliance Program

Companies have to implement a sanctions compliance program (SCP). The Treasury Department Office of Foreign Asset Control’s sanctions guidance issued in May 2019 is an extraordinary document and includes numerous prescriptive requirements.  Companies ignore the SCP Guidance at their peril.   The Treasury Department’s Office of Foreign Asset Control (OFAC) has a robust and mature enforcement program.  Over the last few years, OFAC has successfully expanded its enforcement...

BitMEX Trading Exchange Earns Criminal and Civil Prosecution for AML Violations

We all have been following the rapid growth of cryptocurrency and the creation of lucrative trading platforms.  Cryptocurrency has earned the scrutiny of regulators and criminal prosecutors – not for run-of-the-mill fraud schemes, but for compliance with applicable anti-money laundering laws and regulations. Late in 2020, the Justice Department and the Commodities Futures Trade Commission (“CFTC”) slammed BitMEx and its principals with a coordinated criminal...

New Year Webinars: 2020 FCPA and OFAC Enforcement and Compliance Reviews

2020 FCPA Enforcement and Compliance Trends January 5, 2021, 12 Noon EST Sign Up HERE 2020 OFAC Enforcement and Compliance Trends January 6, 2021, 12 Noon EST Sign Up HERE For FCPA enforcement, 2020 was a record year. The Justice Department collected a record-setting amount of criminal fines for anti-corruption violations, while continuing its aggressive criminal indictment of individuals for FCPA and other criminal offenses....

California Mandates Increased Diversity on Corporate Boards

The United States continues to lag in corporate board diversity.  Many corporate boards are dominated by white males.  Progress on this issue has been slow. The number of women on Russell 3000 boards rose from 15 to 19 percent.  Most of the increase occurred on boards of mid- and large-cap companies.  In 2019, 45 percent of new board members were female and only 15 percent...