There are some things you learn best in calm, and some in storm. Will Cather DOJ has promised an aggressive criminal corporate enforcement program against sanctions violators. The storm is coming and will arrive soon with a bang. There is no question that DOJ’s enforcement initiative is coming — it is just a question as to when. In this Episode, Michael Volkov reviews the elements...
Following the death of opposition politician Alexey Navalny, the Biden Administration announced a large swath of new and additional sanctions on the Russian Federation. The U.S. Department of Treasury’s Office of Foreign Assets Control (”OFAC”), in conjunction with the Department of State and the Department of Commerce, added almost 300 individuals and entities to the Specially Designated Nationals List (“SDN List”). Later in the day,...
As always, I tend to repeat myself. However, one important point needs to be repeated — DOJ is in the midst of launching an aggressive sanctions and export control program against corporations and individuals. DOJ has warned everyone, repeated this message in various speeches and, most importantly, assigned the resources — 25 new federal prosecutors to enforce sanctions and export controls — to back up...
The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has renewed its commitment to squeezing Russia’s oil proceeds, releasing updated guidance with enhanced attestation and record-keeping requirements for maritime shipping operators and other industries that participate in the transport of Russian oil. OFAC also announced sanctions against several firms operating in apparent violation of the Price Cap. The Price Cap Policy is...
When it comes to OFAC sanctions violations, honesty is the best policy. Promptly and voluntarily disclosing violations upon their discovery can pay serious dividends. So was the case for Nasdaq, Inc., which this week settled Iran sanctions violations in what could have been a $458 million OFAC penalty, for just $4.04 million, less than 1% of the applicable statutory maximum. For those who view compliance...
Matt Stankiewicz, Partner at The Volkov Law Group, breaks down Binance’s recent criminal settlement agreements with U.S. regulators. Matt can be reached at [email protected]. On November 21, 2023, The U.S. Department of Justice (“DOJ”) announced settlement agreements with Binance Holdings Limited (“Binance”), the world’s largest cryptocurrency exchange, and Changpeng Zhao (affectionally known as “CZ” in the cryptocurrency industry), the exchange’s founder and Chief Executive Officer...
Rewards programs have become ubiquitous in recent years. These so-called loyalty management programs exist to nudge customers or employees in a particular direction; a company’s workers might be inclined to exercise more regularly, for example, if they know there is a $5 gift card waiting for them after a specified number of gym check-ins. Their rapid expansion and cash-equivalent, pre-paid nature make loyalty management programs...
Each quarter, we send many of our clients a quarterly trade compliance update, highlighting important developments over the last few months and summarizing key points for important sanctions programs. Click here to download the quarterly update for October. Below is a summary of events this past quarter: About the document: This handy one-pager is designed to be used by our clients to provide a quick...
Matt Stankiewicz, socio en The Volkov Law Group PC, se une nuevamente en nuestro blog con una tema de suma importancia, alivios del gobierno de Estados Unidos respecto del programa de sanciones comerciales de Venezuela por parte de la OFAC. Para mayor información: [email protected] El 18 de octubre de 2023, la Oficina de Control de Activos Extranjeros (“OFAC”) del Departamento del Tesoro de los Estados...
The past few weeks have not been kind to 3M. The company recently settled with the SEC for $6.5 million to resolve alleged FCPA violations related to its Chinese subsidiary’s dealings with Chinese state-owned healthcare institutions. Another federal agency, OFAC, yesterday announced that it had settled with 3M for $9.6 million over alleged violations of the Iranian Transactions and Sanctions Regulations. In another OFAC enforcement action, Emigrant Bank (“Emigrant”),...
