The Volkov Law Group is pleased to announce that Stephen Naughton, a legal and compliance industry lawyer, has joined the Volkov Law Group as Senior Counsel. Steve recently joined Loyola University (Chicago) Law School as the Director of Regulatory Compliance Studies and a Clinical Professor. Steve will serve in a part-time role as Senior Counsel to the Volkov Law Group. Steve has more than 30...
What a year for OFAC – Amazon settled its case for OFAC violations and now add Berkshire Hathaway. Lat year, Apple settled with OFAC for sanctions violations. Sanctions compliance is not rocket science – it requires commitment, dedication, expertise and resources. The board and senior management have to understand the importance of sanctions compliance and execute a plan to do so. Unfortunately, it appears like...
Goldman Sachs has a new leadership role – unfortunately, it is for corruption. It would be a serious mistake to characterize or describe the Goldman corruption scheme as the result of a few, bad actors. Instead, Goldman suffered this scandal because of a culture and a weak set of controls crafted to promote business with little regard for compliance. The lessons learned from this massive...
Goldman Sachs now sits atop all charts with the largest US FCPA bribery penalty, totaling approximately $2.9 billion. The second largest is Ericsson’s 2019 FCPA settlement for $1 billion. There is a reason that Goldman “earned” this distinction. The bribery scheme and controls and compliance failures are repugnant and pervasive. Goldman’s corruption scheme was built on stealing funds from the 1MDB account that was intended...
The Justice Department finally closed out its investigation of Goldman Sachs’ massive bribery scheme involving Malaysia’s 1MDB fund. The case is now the largest in US FCPA history (based on its payment to DOJ and related US agencies). Goldman Sachs entered into three-year deferred prosecution agreement (“DPA”) with the filing of a criminal information charging conspiracy to violate the anti-bribery provisions of the FCPA. At...
The Justice Department finally closed out its investigation of Goldman Sachs’ massive bribery scheme involving Malaysia’s 1MDB fund. The case is now the largest in US FCPA history (based on its payment to DOJ and related US agencies). Goldman Sachs entered into three-year deferred prosecution agreement (“DPA”) with the filing of a criminal information charging conspiracy to violate the anti-bribery provisions of the FCPA. At...
Elizabeth Slim, Senior Consultant at The Volkov Law Group, was interviewed on the terrific podcast, Captivated Audience, a Financial Crime Podcast. Captivated Audience is a great podcast hosted by Samantha Sheen and Marie Lundberg, two global financial leaders and experts in the industry. Samantha and Marie interviewed Elizabeth discuss FinCEN’s recent advisory on Politically Exposed Persons (“PEP”), the differing treatment of PEPs in the US...
Shortly before announcing its comprehensive FCPA settlement with DOJ and the SEC, Pilgrim’s Pride agreed with the Justice Department’s Antitrust Division to plead guilty to price-fixing in the chicken processing industry. Pilgrim’s Pride is one of the largest poultry producers in the United States. The plea agreement was restricted to three contracts to a customer in the United States. Under the plea agreement, Pilgrim’s Pride...
J&F Investimentos (“J&F”) FCPA settlement presents a number of important lessons learned. While the bribery scheme was brazen and involved a large amount of money, the techniques and warning signs must have been fairly obvious. Despite J&F’s large global operations and expansion plans, J&F made no apparent effort to build an ethics and compliance program or implement basic compliance requirements, such as a Code of...
In recognition of the impact that Covid-19 has had on global companies involved in export operations, the Commerce Department’s Bureau of Industry and Security announced a streamlined process for companies to request a six-month extension for licenses that are scheduled to expire on or before December 31, 2020. The pandemic has caused significant disruption to global companies distribution channels and supply chains. Air and ocean...
