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OFAC had a big year in 2019 and 2020 looks like a continuation. In the last week, OFAC issued two enforcement actions -- Eagle Shipping (here) and Park Strategies (here). Eagle Shipping Eagle Shipping, a Marshall Islands company, headquartered in Stamford, Connecticut, agreed to pay OFAC $1.125 million to settle
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The Justice Department is often criticized for its lack of transparency. But when it comes to policy changes or initiatives, DOJ is more than transparent – DOJ always tells the public what it plans to do and then does it. When people act surprised about a policy initiative or a DOJ
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The Office of the Comptroller of Currency (OCC) announced a $17.5 million settlement with former Wells Fargo Bank CEO John Stumpf’s role in the sales practices misconduct scandal. In addition, the OCC announced settlements with two other Wells Fargo officials: (1) Hope Hardison, former Chief Administrative Officer and
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In this episode, Tom Fox and Mike Volkov begin a three-part series where they discuss the classic movie A Night at the Opera and how it informs 2019 in compliance, FCPA enforcement actions and ethics/compliance trends. The Episode is available Here.
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Jessica Sanderson, Of Counsel at The Volkov Law Group rejoins us for her annual review of False Claims Act enforcement. Jessica can be reached at jsanderson@volkovlaw.com. 2020 marks the 150th anniversary of the Department of Justice (“DOJ”), and it unwrapped a nice gift: On January 9, 2020, DOJ
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I am reluctant to start off the New Year with a negative comment or posting. But I have a significant concern about the path and current state of ethics and compliance. From my vantage point, I have always been inspired by the forward momentum of the compliance profession. We have
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In an interesting end of year decision, issued on December 31, 2019, a District Court in Dallas issued a rejected OFAC’s enforcement action against Exxon Corporation imposing a $2 million penalty for violation of the Russia Sanctions Program. (Copy of decision is here). OFAC suffered a rare rebuke after
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I usually ignore hyperbole. I cringe when I hear, “[Title] was the greatest movie of all time,” or “[Title] was the greatest book of all time” (true confession -- except if someone fills in the blank with The Brothers Karamazov by Fyodor Dostoevsky). Moving on, 2019 was a big year in
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While DOJ had its biggest year in FCPA enforcement, OFAC quietly had a record year in enforcement. OFAC collected approximately $1.28 billion (yes, with a B) in 26 separate enforcement actions. That is quite an increase over 2018 when OFAC collected $71 million in 7 separate enforcement actions. OFAC
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The path of the compliance profession has been remarkable. Recently, I have seen a number of tweets and postings from compliance thought leaders touting the accomplishments of compliance and the transformation of the profession (e.g. Donna Boehme and Roy Snell). In particular, compliance thought leaders cite the increase of
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As a passionate supporter of the compliance function, I continue to advocate for compliance officers and the importance of compliance to overall governance. Good compliance means good business – we all know that. Compliance always depends on interpersonal skills. A CCO is only as good as his/her ability to persuade
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As everyone knows, I am an eternal optimist. Being a cynic always leads to negative energy and results. As a former federal prosecutor, I am deeply committed to the idea of doing the right thing. There is no meaningful alternative and I am mystified by individuals who can avoid or