General
Matt Stankiewicz, Partner at The Volkov Law Group, continues blog series on the collapse of FTX, looking at the criminal charges filed against founder and CEO Sam Bankman-Fried. He can be reached at mstankiewicz@volkovlaw.com. Following FTX’s stunning collapse, federal prosecutors have quickly taken steps to hold
General
This is a very complicated case, Maude. You know, a lotta ins, a lotta outs, a lotta what-have-yous. And, uh, a lotta strands to keep in my head, man. Lotta strands in old Duder's head. – The Dude, The Big Lebowski Each FCPA case provides valuable lessons
General
Talk about a reminder of the past, Asante Berko, a former Executive Director in Goldman Sachs, recently was arrested in London on criminal FCPA charges arising from his involvement in a bribery scheme in Ghana. The surprising part of the case was the delay in his arrest – over 2 years.
General
We always focus on foreign bribery -- the FCPA and corporate bribery of foreign officials. It is certainly a problem that undermines economic development and human rights. However, bribery and corruption is real and significant in the United States, from local to state to federal government officials, the news is filled
General
It is easy to be dogmatic in blog postings -- to express an unvarnished opinion that sounds valid. While it may not be supported by hard data or valid evidence, compliance officers are used to trusting their "gut feelings," when it comes to compliance. Compliance professionals with experience agree
Podcasts
I have been -- and continue to be-- hyper-focused on the proper role and responsibilities for Chief Compliance Officers. Not that I see any cause for alarm, but it is easy to lose focus in the sea of so-called hot issues -- ESG, Diversity, Climate Change, Threats to Democracy, Cybersecurity
General
As we enjoy the remainder of the summer and get ready to launch into a new fall season (no, not football) but a time for renewal and recommitment, this may be a good opportunity to examine and analyze your own compliance program. DOJ's framework provides a valuable set
General
As Supreme Court Justice Potter Stewart eloquently opined in Jacobellis v. Ohio (1964), on the legal definition of obscenity, "I know it when I see it." This same test applies to other issues as well -- when it comes to an effective ethics and compliance program, and an effective
General
OK, I admit it. I have been -- and continue to be-- hyper-focused on the proper role and responsibilities for Chief Compliance Officers. Not that I see any cause for alarm, but it is easy to lose focus in the sea of so-called hot issues -- ESG, Diversity, Climate Change,
General
The Department of Justice continues to respond to the compliance community's concerns about the new certification requirement adopted as part of the Glencore FCPA enforcement action. DOJ has adopted this new requirement to "empower" CCOs and to ensure that CCOs have a "seat at the
Podcasts
In following the Justice Department and the Securities Exchange Commission FCPA enforcement actions, I am always reminded of the popular phrase — “reading the tea leaves.” (or “tasseography,” a fortune-telling method based on tea leave patterns in tea sediments). Despite a slow initial year in 2021, the Biden Administration’s
Podcasts
The SEC announced another FCPA settlement in 2022. FCPA enforcement, in general, is picking up. Tenaris, a global supplier of steel pipes and related services for the energy industry agreed to pay the SEC $78 million to resolve FCPA violations that occurred in Brazil. The US Department of Justice closed