General
I am excited to announce the addition of Noah Smith as a new Associate at The Volkov Law Group. When I launched the firm, I was committed to providing high-quality ethics and compliance, and enforcement defense services. With the help of my existing members we have been fortunate to
General
Okay, I have to admit – it is getting hard to keep up with all the changes to the Russia Sanctions Program. The Treasury Department, Office of Foreign Asset Control’s imposition of the Oligarch Sanctions (here) and Congress’ passage of the Countering America’s Adversaries Through Sanctions Act (“CAATSA”) (here)
General
Legg Mason can finally close its books on the Gaddafi-era, Libyan bribery scandal. In June 2018, Legg Mason entered into a non-prosecution agreement with the Justice Department and agreed to pay $32 million for its role in the bribery scheme. Société Générale entered into a deferred prosecution agreement
General
Criminal prosecutors understand the importance of cooperating witness to the criminal justice system. Cooperating witnesses are vital to the criminal justice system because they are in the unique position of explaining to a jury the operation of a criminal enterprise. Without insider information, there are numerous criminals and criminal organizations
General
The Justice Department’s attempt to assert broad jurisdiction over foreign nationals was rebuked in a recent US Court of Appeals decision in United States v. Hoskins. (Here). As a result, the appellate court affirmed the lower court’s decision to dismiss the FCPA conspiracy count against defendant Hoskins, a
General
In a recently released letter (here), the Justice Department issued a declination to the Insurance Corporation of Barbados Limited (ICBL) for violations of the FCPA under the FCPA Corporate Enforcement Policy. DOJ required ICBL to pay approximately $93,000 in disgorgement. ICBL paid approximately $36,000 in bribes to Donville
General
The Trump Administration issued a new executive order on August 6, 2018, in order to reimpose the first tranche of the Iran sanctions lifted by the former Joint Comprehensive Plan of Action (“JCPOA”). In doing so, the executive order consolidates relevant sanctions authorities and broadens the scope of the previous
General
There is no universal definition of corruption. Frankly, the term can be narrowly defined to focus on bribery or it can be given a wider application, extending to abuse of power. Transparency International defines corruption as “the abuse of entrusted power for private gain.” Frankly, it depends on the official
General
One of the more esoteric debates among legal scholars focuses on defining corruption and the political roots of anti-corruption efforts. As it turns out, scholars have pointed to the Framers debate and provisions in the U.S. Constitution to support the idea that in creating the United States government,
General
An effective compliance program requires that companies review and improve their compliance programs. A company should regularly review and test its controls, and address potential weaknesses in its compliance program. The Justice Department and the SEC have encouraged companies to conduct regular tests and reviews to create a sustainable compliance
General
Congress enacted the Foreign Investment Risk Review Modernization Act of 2018 (FIRRMA), which was intended to modernize and strengthen the CFIUS process. FIRRMA was incorporated into the National Defense Authorization Act which as passed and signed into law. FIRRMA expands CFIUS jurisdiction to include four new types of transactions, expands
General
Washington, D.C. is more than just the nation’s capital. Companies have to pay attention and develop contacts and relationships in Washington, D.C. given the importance of federal agencies, Congress and of course, the White House. I often inform clients that Washington, D.C. provides a second round