General
In the absence of federal cybersecurity and data privacy laws, companies have to look to other sources of guidance, including industry standards, and state laws. The National Institute of Standards and Technology ("NIST") has sought to fill some of the large gaps on the issue of cybersecurity. Enforcement
Podcasts
LRN continues to set the standard for ethics and compliance program research. Volkov Law is a supporter of, and advocate for, LRN’s research because it has consistently confirmed what we all know and believe — ethical companies perform better in the marketplace over the long run. It is an intuitive
Events
Webinar: Effective Strategies to Handle Whistleblower Complaints May 21, 2024, 12 Noon EST Sign Up HERE Whistleblower reporting is a real and pervasive threat to companies. The Justice Department, the Securities and Exchange Commission and other regulatory agencies offer financial rewards to potential whistleblowers. This new incentive structure poses real
General
NAVEX continues to produce high-quality compliance reports, many of which are a must-read in the compliance industry. Its annual Whistleblower Report is of particular note -- NAVEX is the leading provider of hotline services in the world and its data is invaluable as a source of trends in this
General
OFAC is capable of extending a long-arm of enforcement, reaching sometimes non-U.S. companies that may "cause" another company to violate U.S. Sanctions laws. If you need to find an example of this long reach, look no further than last week's OFAC settlement
General
The Justice Department has a long and rich history of targeting dominant companies using antitrust monopolization tools -- looking back to the 1980s, it was AT&T; in the 1990s, it was Microsoft; and in 2023, DOJ has brought a monopolization case against Google; and meanwhile the FTC filed monopolization
General
As DOJ, OFAC and BIS ramp up sanctions and export controls enforcement, they have continued to provide important compliance guidance. You have to give the enforcement agencies credit -- on the one hand, they regularly warn of the coming enforcement storm and aggressive push against companies and individuals; and on the
Podcasts
On the heels of the Gunvor FCPA settlement for $661 million, DOJ announced its settlement with Trafigura, the latest commodities trading company to fall under DOJ's FCPA Sweep against the industry. Trafigura joined the list of international commodity trading companies to suffer FCPA enforcement actions -- Vitol, Sargeant Marine,
General
The Justice Department is rightly trumpeting its successful sweep of the commodities trading industry. DOJ's success is reflected in its six separate corporate resolutions and 20 individual convictions, resulting in over $1.7 billion in penalties. Companies in the global commodities trading industry should take heed of DOJ&
General
Trafigura's bribery scheme resembles the same schemes implemented by its significant competitors -- Vitol, Glencore, Gunvor. At the core of the conduct, Petrobras and Brazilian government officials collected bribes in exchange for valuable contracts for Petrobras oil. The factual statement reflects DOJ's extensive knowledge base in the
General
On the heels of the Gunvor FCPA settlement for $661 million, DOJ announced its settlement with Trafigura, the latest commodities trading company to fall under DOJ's FCPA Sweep against the industry. Trafigura joined the list of international commodity trading companies to suffer FCPA enforcement actions -- Vitol, Sargeant Marine,
Podcasts
In a recent speech, on March 7, 2024, Deputy Attorney General Monaco announced that DOJ would be implementing in the next 90 days a new whistleblower program to reward reporting of criminal misconduct at both public and private companies. In particular DOJ will encourage reporting of potential violations of the