Corruption, Crime & Compliance

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18 Apr, 2021

Episode 190 — Catching Up on Russia and Burma Sanctions Programs

Last week, the Biden Administration announced new and significant trade sanctions against Russia. The action was long expected given the Biden Administration’s criticism of Russia, and was a comprehensive response to Russia’s interference in the 2020 US election, its SolarWinds cyberattack and its ongoing occupation of Crimea and threatening addition of troops along the Ukraine border. Over the last few months, OFAC has ratcheted up sanctions against...

General

15 Apr, 2021

Where There is No Will, There’s No Way: The Bottom Line for Chief Compliance Officers

The Road to Hell is Paved with Good Intentions – Samuel Johnson, 1775. You can draft and design the best ethics and compliance program – and then fail. You can show every compliance professional an “effective” set of ethics and compliance controls, pristine, drafted elegantly, addressing each and every risk with the perfectly calculated impact, and your program may fail. Why? Paper compliance programs are...

General

13 Apr, 2021

Before Moving on to ESG, Fix Your Speak Up Culture!!

Ethics and compliance has to stand strong when new trends suddenly spring up. Organizations are always ready to embrace the new-fangled shiny object – in this case ESG. Not to be a nattering nabob of negativism (see Spiro Agnew’s comment in 1966 crafted by William Safire), but organizations have to take a deep breath and renew a review of its ethics and compliance program fundamentals. ...

General

12 Apr, 2021

Gunvor Group Former Employee Pleads Guilty to FCPA Scheme to Pay Bribes to Ecuadoran Government Officials

Raymond Kohut, a 68-year old Canadian citizen, a former employee of Swiss commodities trader, Gunvor Group, Ltd., pleaded guilty to paying $22 million in bribes to Ecuadoran government officials at state-owned oil company, PetroEcuador. Kohut pleaded guilty to one count of money laundering conspiracy before a federal judge in Brooklyn, New York, the Eastern District of New York. Kohut agreed to forfeit $2.2 million. Gunvor...

General

12 Apr, 2021

Volkov Law Announcements: Matt Stankiewicz is Promoted to Partner, and Ameer Gopalani, Senior Counsel, Joins the Firm

The Volkov Law Group is pleased to announce the promotion of Matt Stankiewicz to Partner, and the addition of Ameer Gopalani as Senior Counsel to the Firm. Matt Stankiewicz has distinguished himself as a seasoned and talented attorney, who is committed to integrity, ethical values and delivering high-quality, client service. Matt joined the Volkov Law Group in 2013, while completing service as part of the...

General

12 Apr, 2021

Environmental Crime Enforcement: Button Up for an Increase in Criminal Investigations and Compliance Demands

The Biden Administration has a number of enforcement priorities. While not listed as a primary objective, the Justice Department and the EPA can be expected to increase criminal enforcement of environmental laws. DOJ’s Environmental Crimes Section (ECS) has had a steady enforcement record but has suffered political ups and downs depending on the political leanings of the administration in power. The critical issue is usually...

General / Podcasts

11 Apr, 2021

Episode 189 — A Review of the ESG Movement

ESG is firmly implanted in the corporate governance landscape. Prosecutors and regulatory agencies are quickly adding ESG to their lexicon. The real question for every organization is “what are you doing to address it?” ESG is a terrific opportunity to leverage an organization’s corporate culture to address a broad set of values beyond ESG principles. In this Episode, Michael Volkov discusses the ESG movement and...

General

8 Apr, 2021

Spring Cleaning: Time to Review Your Internal Controls

There are a lot of so-called “dirty secrets” in the corporate governance world. Not the tawdry kind that appear to follow controversial politicians – I mean in the world of internal controls. I would wager that most companies cannot even identify all of the policies, procedures and controls that have been created during the life of the company. Some exist in what I call the...

General

7 Apr, 2021

Biden Administration Ramping Up Anti-Corruption Effort

The Biden Administration is taking over the reins of government with vigor and focus. The Department of Justice, the Treasury Department, the State Department and the Commerce Department are expected to coordinate closely in an important objective – international anti-corruption efforts. What will this mean? DOJ will increase its focus on FCPA enforcement, Anti-Kleptocracy cases, Anti-Money Laundering, International Trade Sanctions; The Treasury Department’s Office of...

General

6 Apr, 2021

Antitrust Division Charges Health Care Staffing Company with Criminal Wage-Fixing and No-Poaching Agreement

The Justice Department’s Antitrust Division is pushing criminal enforcement against companies for illegal wage-fixing among competitors in the hiring market. After years of warning companies that DOJ intended to prosecute criminal cases for illegal cartel activity in labor markets, DOJ is delivering on its warning. In its third announced criminal case, DOJ has indicted VDA OC, LLC, a health care staffing company that supplied nurses...