Tagged: due diligence

Five Practical Steps to Elevate Your Sanctions Compliance Program (Part III of III)

Even with the current focus on sanctions compliance, many companies have done little to assess and enhance their existing sanctions compliance program.  Instead, a number of companies have stitched together a basic sanctions compliance program that centers on a screening tool and little beyond that.  Such a limited program provides just a  false comfort of compliance.  Many companies are not even conducting the mandated basic...

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...

Flutter Entertainment Settles SEC FCPA Case for $4 Million for Improper Payments to Russian Consultants

Flutter Entertainment Settles SEC FCPA Case for $4 Million for Improper Payments to Russian Consultants

Flutter Entertainment, the previous owner of PokerStars, agreed to pay the Securities and Exchange Commission $4 million for improper payments to Russian-based consultants, stemming from conduct committed by The Stars Group, PokerStars previous owner.  Flutter purchased PokerStars in 2020. Flutter is an Ireland-based global gaming and sports betting company. Flutter was tagged with the FCPA violations committed by the Stars Group prior to Flutter’s acquisition. ...

LRN 2023 Compliance Program Report Underscores Importance of Compliance Program Vigilance

LRN 2023 Compliance Program Report Underscores Importance of Compliance Program Vigilance

LRN continues to provide important insights and trends on the importance of ethics and compliance programs.  LRN’s annual report is an important resource and needs to be reviewed by the board, senior management and all compliance-related functions. LRN’s 2023 report emphasizes the importance of commitment, investment and promotion of corporate ethics and compliance, particularly during these difficult economic and geopolitical disturbances. LRN’s report is based...

2022: The FCPA Year in Review

2022: The FCPA Year in Review

The Justice Department and the Securities and Exchange Commission bounced back in 2022 to restore their records for aggressive FCPA enforcement.  At the same time, DOJ announced significant new compliance program expectations, and appeared ready to press forward with a number of FCPA resolutions. The Numbers For the year, DOJ totaled five corporate resolutions, two separate declinations under its Corporate Enforcement Policy, and approximately 24...

The Fall of FTX: The Legal Ramifications of the Collapse of Sam Bankman-Fried’s Cryptocurrency Empire (I of IV)

The Fall of FTX: The Legal Ramifications of the Collapse of Sam Bankman-Fried’s Cryptocurrency Empire (I of IV)

Matt Stankiewicz, Partner at The Volkov Law Group, joins us with a comprehensive blog series that will breakdown the various legal issues facing the fallen cryptocurrency exchange FTX and its disgraced founder Sam Bankman-Fried.  He can be reached at [email protected]. The cryptocurrency world is in shock watching the events unfold around the stunning collapse of FTX, one of the largest crypto exchanges in the world.  The...

Episode 243 — Scott Greytak, Transparency USA, and Erica Hanichak, the FACT Coalition, on House Passage of The Enablers Act

In a bipartisan success story, the House recently passed The Enablers Act, which is a far-reaching reform bill aimed at reducing AML and corrupt financial activity in the United States. Scott Greytak, Advocacy Director at Transparency International USA, and Erica Hanichak, Director of Government Affairs at the FACT Coalition, join Michael Volkov for a discussion of this legislative accomplishment and the implications for the battle...

DOJ Compliance Program Certification Requirements (Part I of III)

DOJ Compliance Program Certification Requirements (Part I of III)

The Department of Justice continues to respond to the compliance community’s concerns about the new certification requirement adopted as part of the Glencore FCPA enforcement action.  DOJ has adopted this new requirement to “empower” CCOs and to ensure that CCOs have a “seat at the [senior management] table.”  While these are all laudable goals, CCOs continue to question whether DOJ’s new certification requirement will undermine...

Episode 239 — DOJ’s New CCO Certification Requirement

Episode 239 — DOJ’s New CCO Certification Requirement

The Department of Justice continues to respond to the compliance community’s concerns about the new certification requirement adopted as part of the Glencore FCPA enforcement action. DOJ has adopted this new requirement to “empower” CCOs and to ensure that CCOs have a “seat at the [senior management] table.” While these are all laudable goals, CCOs continue to question whether DOJ’s new certification requirement will undermine their authority...

Private Attorneys General: Enforcing Human Rights Through Corporate Supply Chain and Risk Management (Part I of II)

The Volkov Law Group is pleased to announce our first, official summer internship program. We have welcomed a diverse group of talented, intelligent, and driven college students, who are interested in pursuing legal or compliance careers. In this blog article, our intern Abigail Schuman, a rising junior at the University of Wisconsin, discusses certain legislation aimed at combatting slave labor and human trafficking in corporate...