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Episode 81 — Update on OFAC Enforcement and Compliance Lessons Learned

OFAC is off to a fast start in 2019.  It has implemented enhanced Venezuela sanctions and designated PDVSA as a Specially Designated National, and brought four separate enforcement actions with important lessons learned for sanctions compliance. In this Episode, Michael Volkov reviews OFAC’s actions and outlines important sanctions compliance lessons learned.

2019 Cryptocurrency Regulations – A Primer and What to Expect Throughout the Year

Matt Stankiewicz, Senior Counsel at The Volkov Law Group, rejoins us for an interesting posting on 2019 cryptocurrency trends and regulations. Matt can be contacted at [email protected] You’ve heard this before, but it still holds true – cryptocurrency regulations are coming.  Everyone knows they’re inevitable, and there has been some trepidation amongst investors that regulations will disrupt innovation and just generally cause a mess within...

Lessons Learned and Trends from MTS FCPA Enforcement Action and Criminal Indictment of Karimova and Akhmedov (Part III of III)

The MTS FCPA enforcement action stands as one of several significant prosecutions in FCPA history.  The breadth and depth of MTS’ corruption scheme stands as another example of systemic bribery cultures.  The details of the enforcement action underscore several important trends and enforcement policies.  Let’s review some of the more significant lessons learned and trends. Application of FCPA Corporate Enforcement Policy: MTS was not able...

Anatomy of MTS, Karimova and Akhmedov Bribery Scheme in Uzbekistan (Part II of III)

The MTS bribery scandal in Uzbekistan represents the culmination of several significant FCPA violations involving VimpelCom, Telia Sonera, MTS, and Gulnara Karimova, the notoriously corrupt daughter of the former Uzbek President.  Karimova is perhaps one of the most notorious corrupt offenders in the world.  She has been under house arrest in Uzbekistan since 2014. (Indictment Here). According to MTS’ admissions, MTS and its subsidiaries, Uzdunrobita...

Russian Mobile Carrier, Mobile Telesystems, Settles FCPA Case with DOJ and FCPA for $850 Million; MTS Executive and Notorious Uzbek Government Official Indicted (Part I of III)

In another blockbuster FCPA prosecution, the Justice Department and the SEC announced an $850 million settlement with Mobile Telesystems (“MTS”), Russia’s largest mobile carrier.  At the same time, the Justice Department announced criminal indictments against an MTS executive and the notorious corrupt Uzbek official, Gulnara Karimova, on criminal charges. MTS is the largest mobile telecommunications company in Russia, and has stock that is publicly-traded in...

Episode 80 — Best Practices for Investigation of Allegations of Sexual Misconduct in the #MeToo Era

The corporate governance landscape is littered with companies that have suffered major legal and reputational damage as a result of failure to promote and protect a safe workplace environment.  Companies have failed to hold offenders accountable for sexual misconduct and violation of applicable legal and code requirements. The #MeToo era has resulted in increased reporting of sexual misconduct allegations and requires enhanced monitoring of corporate...

DOJ Sweeps Up Two More Defendants in PDVSA Criminal Investigation

The Justice Department’s sprawling and successful prosecution of bribery and money laundering surrounding PDVSA, Venezuela’s state-owned energy company, shows no signs of letting up.  DOJ’s prosecutions began in 2015, and with the recent announcement of two new defendants, DOJ’s scorecard has reached a total of 21 defendants, 15 of whom have pleaded guilty.  Given PDVSA’s reputation for corruption, which is well earned (or as I...

Webinar: Best Practices for Internal Investigations of Sexual Misconduct Allegations in the #MeToo Era

Webinar: Best Practices for Investigation Sexual Misconduct Allegations in the #MeToo Era March 26, 2019, 12 Noon EST SIGN UP HERE The corporate governance landscape is littered with companies that have suffered major legal and reputational damage as a result of failure to promote and protect a safe workplace environment. Companies have failed to hold offenders accountable for sexual misconduct and violation of applicable legal...

OFAC Announces Yet Another Enforcement Action – Cement Clinker Company Settles for Violations of Iran Sanctions Program

OFAC is definitely off to a fast start this year – it recently announced its fourth enforcement action for 2019.  So far, OFAC has collected over $7 million in civil penalties.  While this may not appear to be a lot of money in civil penalties, it is important to remember the consequences of an OFAC settlement and scrutiny for future violations, restrictions on exports, and...

DOJ Arrests Micronesian Official and Hawaii-Based Businessman Pleads Guilty to FCPA Violation

In January 2019, the Justice Department brought an interesting FCPA prosecution involving a Hawaii-based businessman, Frank James Lyon, and Master Halbert, a government official from Micronesia.  DOJ’s prosecution was interesting for two significant reasons – first, it was another example of DOJ enforcement efforts against the payor of the bribe for violating the FCPA and the recipient of the bribe, the foreign official, for money...