Sorry to start a four-part series with a reference to music from our long-ago past.  The Four Tops sang the “Same Old Song, with a Different Meaning” (released in 1965 — Video Here). So, how does that relate to third-party risks?  Well, bear with me here for a little. Legal and Compliance bloggers, compliance vendors, prognosticators, Compliance Podcasters, and everyone in the Paparazzi have written,...

News recently published by multiple media outlets suggest that certain subcomponents incorporated into a variety of Volkswagen-owned vehicles—including cars manufactured by luxe brands Porsche, Bentley and Audi—were sourced from an unspecified region in “western China” (“PRC”) presumed to be the Xinjiang Uyghur Autonomous Region (“XUAR”). According to these sources, Volkswagen itself was not aware of the origin of the part, which, according to the Financial...

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 January. Below is a summary of events this past quarter: Venezuela –  Russia –  Middle East –  General –  About the document: This handy one-pager is designed to...

October 24, 2023 12 Noon EST Sign up HERE The Department of Justice warned global companies of a new, aggressive strategy for enforcement of trade sanctions and export controls. DOJ’s message has been reinforced by the Departments of Treasury (Office of Foreign Asset Control, or “OFAC”) as to sanctions, and the Department of Commerce (Bureau of Industry and Security, or “BIS”), as to export controls....

The Department of Treasury’s Office of Foreign Asset Control (“OFAC”) continues to bring sanctions enforcement actions.  At the same time, OFAC is reiterating the importance of sanctions compliance program.  Building on its May 2019 Framework for Sanctions Compliance Program, OFAC is sticking to its word — setting forth sanctions compliance program requirements and holding companies accountable for sanctions program violations. In this Episode, Michael Volkov...

Well, we are still waiting for the “big” FCPA enforcement actions.  Do not get me wrong – they are coming.  My suspicion is that they are being held up and calculated with a splash to announce the results of the White House’s Global Anti-Corruption Memorandum focusing on the anti-corruption effort as a national security priority.  The landscape is ready for a splash and DOJ is...

Companies with supply chains stretching into China and Xinjiang are facing a mountain of compliance challenges.  Over the summer, the Biden Administration has taken numerous aggressive steps to pressure China to address human rights violations in the Chinese province of Xinjiang focusing on the repression of more than a million Uyghurs in that region. Those companies that maintain  supply chains anywhere in Xinjiang have to...

Mike Volkov interviews Alex Cotoia, Regulatory Manager and Compliance Consultant at the Volkov Law Group, concerning trade compliance and anti-boycott issues. Alex specializes in corporate risk assessments, evaluation of general compliance programs, and the remediation of compliance deficiencies. He also specializes in trade (export) compliance and is familiar with a broad range of issues arising under both the Arms Export Control Act and its implementing...