Tagged: Department of Justice

20 Mar, 2024

Gunvor’s Blockbuster FCPA Settlement: Lessons Learned and Trends (Part III of III)

The Department of Justice’s blockbuster FCPA settlement with Gunvor restores the credibility of DOJ’s pronouncements of DOJ’s commitment to aggressive FCPA enforcement. While I have questioned DOJ’s commitment to its corporate enforcement policy in recent high-profile settlements (ABB and SAP, in particular), DOJ’s Gunvor settlement of $661 million stands as the ninth largest FCPA settlement in history. DOJ’s settlement is proportionate to the misconduct and...

General

19 Mar, 2024

Gunvor’s Bribery Schemes — Third-Parties, Shell Companies and Evasion of Controls (Part II of III)

Gunvor’s bribery scheme is not very surprising nor ingenious. After all, a number of energy trading companies have been prosecuted for bribery over the years, including Glencore, Vitol, Freepoint. Numerous individuals have been prosecuted, convicted and some have cooperated. The global energy trading market presents numerous risk factors — large and valuable energy products (oil, gas etc.) are controlled by foreign-owned companies. All of these...

General

18 Mar, 2024

Gunvor Falls Under FCPA Axe and Agrees to Pay Criminal Penalty of $661 Million (Part I of III)

You have to give the Justice Department credit — after two slow enforcement years, DOJ is starting off 2024 with a relative “bang;” first, DOJ reached a large settlement with SAP in January, and now, DOJ has reached a blockbuster settlement with Gunvor S.A. for $661 million. Gunvor is one of the world’s largest commodities trading companies. DOJ’s settlement represents a “return” to its long-standing...

Podcasts

3 Mar, 2024

Episode 311: Tom Fox on FCPA Enforcement — DOJ’s Approach to Recidivism and Self-Disclosure

In this special episode of Corruption, Crime, and Compliance, Michael Volkov joins colleague and long-time friend Tom Fox as they delve into the intricacies of recent FCPA enforcement actions, shedding light on the evolving landscape of corporate compliance. From the ABB case to the SAP settlement, Michael and Tom dissect the nuances of voluntary disclosure, extensive remediation, and the shifting priorities of the Department of...

General

18 Oct, 2023

Electronic Communications Risks — DOJ Enters the Fray in March 2023 (Part II of III)

Just to play devil’s advocate (or perhaps to push my agenda), I have conflicting views on corporate use of ephemeral messaging applications. On the one hand, I understand the importance of managing electronics communications data, prioritizing the preservation of relevant data, and reducing attendant costs from managing ever-growing amounts of electronic data. On the other hand, as a former prosecutor and now defense counsel, I...

Events

26 Jun, 2023

Volkov Law TV Offers New You Tube Compliance Channel

The Volkov Law Group is pleased to announce its new free, Volkov Law You Tube Channel, which offers a library of nearly ten (10) years of webinar videos. Volkov Law TV includes 132 webinar videos on a variety of enforcement and compliance topics. Please Subscribe to the Volkov Law TV Channel Here. The topics include:

General

24 May, 2023

DOJ’s Enforcement and Compliance Changes: Weighing the Pros and Cons of Voluntary Disclosures

The Justice Department certainly has altered the landscape of enforcement, compliance priorities, and ultimately corporate decisions surrounding voluntary disclosure. It has become a little bit more complicated to sort out all the carrots and sticks. One thing is clear – DOJ wants more companies to voluntarily disclose misconduct. And that is understandable. DOJ does not want companies to wait until they receive a grand jury...

General

10 May, 2023

A Five Step Program for Every Company to Address the New Enforcement Threats

Companies have to demand a new focus from their CEOs, senior executives and legal compliance team in response to the new DOJ and regulatory initiatives. These steps are not just suggestions nor items that can be prioritized based on resources. Instead, these are essential and basic requirements that will inevitably result in significant benefits across the company. Step 1: Define, Embed and Monitor Corporate Culture...

Podcasts

8 May, 2023

Episode 273 — British American Tobacco’s $629 Settlement for Evasion of North Korean Sanctions

The Justice Department warned companies that sanctions enforcement is the “new FCPA.” Recently, DOJ delivered its first salvo to back up its message. As part of a broad effort to prosecute funding of North Korea’s nuclear program, DOJ and the Office of Foreign Assets Control (“OFAC”) announced a joint settlement with British American Tobacco and its Asian marketing subsidiary (“BAT”), under which BAT agreed to...

General

19 Dec, 2022

The Department of Justice Charges FTX CEO Sam Bankman-Fried in the Southern District of New York (II of IV)

Matt Stankiewicz, Partner at The Volkov Law Group, continues blog series on the collapse of FTX, looking at the criminal charges filed against founder and CEO Sam Bankman-Fried. He can be reached at [email protected]. Following FTX’s stunning collapse, federal prosecutors have quickly taken steps to hold FTX’s founder and CEO Sam Bankman-Fried (“SBF”) accountable. On December 13, the Department of Justice (“DOJ”) announced a criminal...

Tagged: Department of Justice

Gunvor’s Blockbuster FCPA Settlement: Lessons Learned and Trends (Part III of III)

Gunvor’s Bribery Schemes — Third-Parties, Shell Companies and Evasion of Controls (Part II of III)

Gunvor Falls Under FCPA Axe and Agrees to Pay Criminal Penalty of $661 Million (Part I of III)

Episode 311: Tom Fox on FCPA Enforcement — DOJ’s Approach to Recidivism and Self-Disclosure

Electronic Communications Risks — DOJ Enters the Fray in March 2023 (Part II of III)

Volkov Law TV Offers New You Tube Compliance Channel

DOJ’s Enforcement and Compliance Changes: Weighing the Pros and Cons of Voluntary Disclosures

A Five Step Program for Every Company to Address the New Enforcement Threats

Episode 273 — British American Tobacco’s $629 Settlement for Evasion of North Korean Sanctions

The Department of Justice Charges FTX CEO Sam Bankman-Fried in the Southern District of New York (II of IV)

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