Tagged: sanctions

Webinar: “The New FCPA”: Sanctions and Export Control Enforcement

Webinar: “The New FCPA”: Sanctions and Export Control Enforcement Tuesday, June 6, 2023, 12 Noon EST Sign Up HERE Last year, the Department of Justice warned global companies of a new, aggressive strategy for enforcement of trade sanctions and export controls. Deputy Attorney General Lisa Monaco stated that sanctions and export enforcement constituted “The New FCPA.” DOJ, the Treasury Department’s Office of Foreign Asset Control...

Episode 266 — Joint Compliance Notice Issued on Sanctions and Export Controls Evasion

As we have noted on numerous occasions, the U.S. Russia Sanctions and Export Control Program is unprecedented and a compliance challenge for all organizations.   In another unprecedented action, the Justice Department and the Departments of Commerce and Treasury issued a Joint Compliance Note (“JCN”) on the importance of compliance with the Russia Sanctions and Export Control requirement, which provides important descriptions of red flags and...

Episode 254 — Update on Export Controls and Sanctions: Interview with Alex Cotoia

This week’s show discusses recent developments in the sphere of export controls and sanctions. Alexander Cotoia, Regulatory Compliance Manager at the Volkov Law Group, joins Michael Volkov to explore the the Department of Commerce’s Bureau of Industry and Security (“BIS”) ramping up of export control enforcement, including the new restrictions on China and Russia. In early October, the BIS announced two rules imposing significant export...

Kraken Coughs Up $362,158 to OFAC to Settle Iran Sanctions Violations

Cryptocurrency companies are in trouble.  Regulators are bearing down on crypto companies with the Eye of Sauron – pulling the crypto companies into their jurisdiction, prosecuting fraud cases, and aggressively prosecuting companies for sanctions and anti-money laundering violations.  One by one you can bet that crypto companies will be in the enforcement headlines.  As they fall, policy makers can point to their continuing excesses as...

Episode 222 — Managing Third-Party Sanctions Risks

Economic sanctions enforcement is a fast-rising risk for global companies. For many years, the Treasury Department’s Office of Foreign Asset Control (“OFAC”) focused primarily on financial institutions. Over the last ten years, OFAC has stretched its enforcement eyes towards software, manufacturing, telecommunications and technology companies. With this growth in sanctions enforcement, OFAC has embraced an aggressive view of third-party risks. Like the FCPA, under OFAC’s regime, third parties...

2022 Ethics and Compliance Predictions

Choose to be optimistic. It feels better.” – Dalai Lama Forgive me for my optimism.  It is the only way to live a meaningful life.  Or as some would say – being a pessimist is too much of a burden.  We begin a New Year — and I am optimistic. To turn the corner here on relevance, ethics and compliance professionals, are by definition, optimists. Give...

various cryptocurrency on table

Takeaways from OFAC’s Sanctions Compliance Guidance for Virtual Assets and Cryptocurrency

Matt Stankiewicz, Partner at The Volkov Law Group, joins us for a post on sanctions compliance in the cryptocurrency industry. Matt can be contacted at [email protected]. In early October, OFAC released a guidance brochure on sanctions compliance, specifically tailored for the cryptocurrency and virtual assets industry.  For seasoned compliance veterans, it ends up reading like a refresher course for sanctions compliance.  While the guidance was...

Biden Administration Ramping Up Anti-Corruption Effort

The Biden Administration is taking over the reins of government with vigor and focus. The Department of Justice, the Treasury Department, the State Department and the Commerce Department are expected to coordinate closely in an important objective – international anti-corruption efforts.  What will this mean? DOJ will increase its focus on FCPA enforcement, Anti-Kleptocracy cases, Anti-Money Laundering, International Trade Sanctions; The Treasury Department’s Office of...

Videoconferencing and Export Controls

Janet Longo, Regulatory Compliance Analyst at The Volkov Law Group, joins us for a posting on videoconferencing and compliance export controls. Janet can be reached at [email protected]. As the Covid-19 virus is proliferating, so is the practice of conducting business through videoconferencing from home. While many commentators have discussed the serious data privacy and security problems associated with video conferencing, we’ve been thinking about the...

OFAC Announces Russia Sanctions Settlement with Software Company

The Department of Treasury’s Office of Foreign Asset Control (“OFAC”) recently announced a settlement against Cobham Holdings (and its former subsidiary Aeroflex/Metelics, Inc. (“Metelics”, a software company) for $87,507 for violations of OFAC’s Ukraine-Russia sanctions program.  (OFAC announcement here). Metelics violated the Ukraine-Russia sanctions program on three occasions between July 31, 2014 and January 15, 2015,  by selling telecommunications and computer software (3,400 switch limiters;...