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The Justice Department's FCPA enforcement record for 2024 was slow. This trend was unexpected, contrary to my own predictions and of various other prognosticators. It is hard to explain why this slowdown occurred. DOJ's record is hard to square against DOJ official speeches, statements and policy
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While 2023 was a relatively slow year in FCPA enforcement, the DOJ and SEC settlements announced throughout the year set out a list of important ethics and compliance reminders. While these may seem obvious to everyone, I hope they stimulate further reflection and analysis to inform FCPA compliance practitioners as
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FCPA trends often are relatively easy to describe and often overblown as a marketing technique by the usual cast of paparazzi suspects. (Self-proclaimed prognosticators that often push incorrect themes to promote business, or those that restate profound grasps of the obvious). 2023 has been a strange year in a
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This article was jointly authored by Alexander J. Cotoia, Regulatory Compliance Manager at The Volkov Law Group, and Daniela Melendez, Associate at The Volkov Law Group. Alexander and Daniela may be reached at their respective email addresses of acotoia@volkovlaw.com and dmelendez@volkovlaw.com. On December 14, 2023, Congress
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Alexander J. Cotoia currently serves as the Regulatory Compliance Manager at The Volkov Law Group, where he regularly advises the firm and its clients on the latest developments implicating trade compliance concerns. He may be reached at acotoia@volkvovlaw.com. On December 22, 2023, President Joseph R. Biden, Jr. issued
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In November 2023, HHS-OIG issued a comprehensive document, the General Compliance Program Guidance ("GCPG"), which outlines important compliance guidance for the healthcare industry. The GCPG provides specific guidance on compliance with the Federal anti-kickback statute ("AKS"), the Physician Self-Referral Law ("Stark Law&
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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
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Join Diligent and The Volkov Law Group for a webinar on January 16, 2024 that explores the complexities of modern slavery and human rights compliance within the realm of third-party risk management. As organizations face heightened scrutiny and increasing expectations to uphold ethical standards, understanding and navigating the evolving
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Within the specific element discussions in HHS-OIG's Guidance, are important operational details and strategies for an effective compliance program. GCPG provides important suggestions and innovations for consideration by all compliance professionals. Effective Lines of Communication The GCPG stresses the importance of an open line of communication between
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To all our clients, family, friends and colleagues, The Volkov Law Group wishes everyone Happy Holidays and Happy New Year! Our blog, webinar and podcast services will resume on January 3, 2024. In the meantime, we wish everyone peace, gratitude. joy and love!! Mike, Matt, Alex, Sam, Daniela and Ben!
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Board Oversight of the Compliance Program The GCPG cross-references the US Sentencing Guidelines board responsibility requirements of the organization's compliance program, and provides that the board shall "be knowledgeable about the contents and operation of the compliance and ethics programs and shall exercise reasonable oversight"
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The health care industry has a rich history of commitment and innovation in developing effective compliance programs. Going back to the 1990s, HHS elevated compliance program requirements for healthcare companies. Many of these innovations translated into strategies that became essential to the compliance industry. For example, in the 1990s, HHS&