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Alex Cotoia, Regulatory Manager at The Volkov Law Group, rejoins us for a review of OFAC's recent settlement with Tango Card for sanctions violations. Alex can be reached at acotoia@volkovlaw.com. On September 30, 2022, the United States Department of the Treasury’s Office of Foreign Asset
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The global economy and geopolitical trends have elevated the importance of trade compliance status and responsibilities. We have witnessed a dramatic increase in the complexity and risks surrounding economic sanctions and export controls. Trade compliance professionals have to navigate a rapidly changing set of regulations. Backing these rules and regulations
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In the legal and compliance space, it is easy to ignore significant incidents involving domestic bribery and fraud. We are fixated on FCPA foreign bribery cases, as well as domestic healthcare fraud, anti-kickback violations and Stark Law incidents. But when it comes to significant domestic fraud, the Justice Department
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You have to give Antitrust Division Assistant Attorney General Jonathan Kanter credit. He sticks to his principles, his priorities and his integrity. AAG Kanter has launched an aggressive antitrust enforcement program with mixed results so far. AAG Kanter understands one important thing -- it takes time to turn around antitrust law
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The Securities and Exchange Commission’s bread-and-butter enforcement actions focus on accounting fraud. The SEC has a long history in uncovering fraudulent financial reporting schemes. In the early 2000s, Wall Street was shaken by a number of scandals involving financial reporting fraud which eventually resulted in passage of
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The Treasury Department's Financial Crimes Enforcement Network ("FinCEN") issued its final rules implementing the beneficial ownership reporting requirements pursuant to the bipartisan Corporate Transparency Act ("CTA"). The rule requires most companies, limited liability and other entities that are registered to do business in the
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The Office of Foreign Assets Control ("OFAC") has demonstrated its ability to multi-task -- designing, implementing and enforcing a comprehensive sanctions regime against Russia after its invasion of Ukraine, and maintaining its "regular" enforcement program. In a recent two-fisted settlement, OFAC reached two separate settlements
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In a significant action, the Justice Department brought criminal charges against the notorious Russian Oligarch, Oleg Deripaska, for sanctions evasion and obstruction of justice. DOJ also charged three associates, Natalya Bardakova, a Russian citizen, Olga Shriki, a New Jersey resident and United States citizen, and Ekaterina Voronina, Deripaska's
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Oracle's SEC settlement for $23 million underscores the power of the FCPA provisions mandating effective internal controls and accurate books and records. As everyone knows, these provisions can be applied to a wide-range of conduct beyond foreign bribery. The SEC recognizes the power of these provisions and
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Oracle Corporation settled its second FCPA case in ten years. Oracle agreed to pay $23 million to resolve allegations that its subsidiaries in Turkey, India and the United Arab Emirates maintained slush funds to bribe foreign officials. Ten years ago in 2012, Oracle paid the SEC $2 million creating millions
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The Justice Department is putting every business on notice -- aggressive white collar criminal enforcement is here to stay. In a one-two punch, Deputy Attorney General Lisa Monaco announced a revised Corporate Enforcement Policy, and Criminal Division Assistant Attorney General Kenneth Polite followed up with a speech outlining the steps
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The Lisa Monaco Memo is a new and important restatement of the Justice Department's approach to corporate crime. It is a worthy read and it sets out a number of new requirements and procedures for DOJ prosecutors investigating corporate crime. In this posting, we return to review a