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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
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NAVEX continues to be one of the premier sources of essential annual benchmarking studies. Recently, NAVEX issued its 2022 Definitive Risk and Compliance Benchmark Report. The Report was based on over 1100 survey responses from compliance professionals around the world. From the topline view, NAVEX reported that organizations have successfully
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We constantly hear about the importance of "accountability," meaning that organizations and individuals have to be held accountable for misconduct or failures to act. The focus on accountability is a positive trend, consistent with our ideas of justice and fairness, Within an organization, accountability is a cornerstone of
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The Department of Justice is pushing its commitment to voluntary disclosure programs. Companies, however, are not lining up at DOJ's door. The balance between sitting tight or voluntary disclosures requires care. To complicate matters further, in certain cases, regulated companies have to face civil enforcement issues and coordinate
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The Department of Justice and many regulatory agencies have rolled out the red carpet for companies to cross the threshold and voluntarily disclose criminal conduct in the hopes of gaining leniency, immunity and reduced fines and penalties. From DOJ's perspective, a voluntary disclosure program increases DOJ's
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The Justice Department promised aggressive enforcement of export controls and sanctions against Russia. To that end, DOJ initiated the KleptoCapture task force to focus law enforcement investigations of export violators. DOJ and the KleptoCapture task force have delivered. The first significant case confirms the importance of tracking DOJ and law
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The Antitrust Division announced last year that it intended to reinvigorate enforcement of Section 8 of the Clayton Act, which prohibits directors and officers serving simultaneously on the boards of competitors (with limited exceptions). Assistant Attorney General Jonathan Kanter continues to implement his aggressive agenda unfazed by his mixed record
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The Justice Department continues to push an aggressive agenda against businesses. It is committed to demonstrating its resolve to prosecute companies and individuals from the business community. Whether it is antitrust, FCPA, False Claims Act, or other assorted white collar crimes, DOJ continues to demonstrate its focus on white collar
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The Department of Treasury's Office of Foreign Assets Control ("OFAC") issued a finding of violation ("FoV") to Nodus International Bank, Inc. ("Nodus"), located in Puerto Rico, for violation of Venezuelan Sanctions. Nordus voluntarily disclosed three unauthorized transactions in which a Specially Designated
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Matt Stankiewicz, Partner at The Volkov Law Group, continues his discussion of recent enforcement actions by OFAC and FinCEN. He can be reached at mstankiewicz@volkovlaw.com. In parallel with the Office of Foreign Assets Control (“OFAC”), the Financial Crimes Enforcement Network (“FinCEN”) settled with Bittrex, Inc. (“Bittrex”), a cryptocurrency
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Matt Stankiewicz, Partner at The Volkov Law Group, joins us for a posting on sanctions compliance in the cryptocurrency industry. He can be reached at mstankiewicz@volkovlaw.com. On October 11, 2022, the Office of Foreign Assets Control (“OFAC”) and the Financial Crimes Enforcement Network (“FinCEN”) announced settlement agreements with
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Alex Cotoia, Regulatory Manager at The Volkov Law Group, rejoins us for an important posting on new Commerce Department rules relating to computer product exports to China. Alex can be reached at acotoia@volkovlaw.com. On October 13, 2022, the U.S. Department of Commerce’s Bureau of Industry and