Podcasts
The Justice Department has repeated on several occasions that it intends to aggressively prosecute corporations for sanctions and export controls violations. The "New FCPA" is how the Justice Department characterizes its plan. To execute the strategy, DOJ has assigned 25 new prosecutors. This is the most important fact
General
Checklists can be handy -- by simplifying and focusing on specific issues, a checklist can organize thinking and prioritize tasks. Here are five (5) questions that are fairly simple but revealing as to whether a company's Sanctions Compliance Program ("SCP") is effective. This is not an exhaustive
Podcasts
With the beginning of the era of the “New FCPA,” as coined by DOJ’s Deputy Attorney General Lisa Monaco, we now need to focus on third-party risk and sanctions enforcement. The law, the practice and the risks are important and not just the same as FCPA legal requirements.
General
Sorry to start a four-part series with a reference to music from our long-ago past. The Four Tops sang the "Same Old Song, with a Different Meaning" (released in 1965 -- Video Here). So, how does that relate to third-party risks? Well, bear with me here
General
If companies operated with perfect governance mechanisms and controls, they would all be ready for the coming sanctions enforcement storm. However, that is not the corporate reality. Even after several companies are the subjects of these aggressive enforcement actions, corporate boards, senior risk managers and senior executives will turn to
Podcasts
Even with the current focus on sanctions compliance, many companies have done little to assess and enhance their existing sanctions compliance program. Instead, companies have stitched together a basic sanctions compliance program that centers on a screening tool and little beyond that. Such a limited program provides just a false
General
Microsoft’s remedial steps provide important best-practices for companies facing similar risk factors in the global economy, especially for global software companies that rely on Internet-based operations. According to OFAC, Microsoft demonstrated a reckless disregard for U.S. sanctions by failing to identify that over a seven-year
Podcasts
The Episode is available HERE. Matt Stankiewicz, a Partner at Volkov Law, is a leading industry expert on cryptocurrency. Bittrex, a leading cryptocurrency exchange, suffered twin enforcement actions for AML and Sanctions Compliance deficiencies. Matt takes a deep dive on the enforcement actions and outlines practical compliance steps that every
General
Jessica Sanderson, Partner at the Volkov Law Group, re-joins us for a posting on a recent OFAC enforcement action. Jessica can be reached at jsanderson@volkovlaw.com. Some may dismiss OFAC’s recent announcement last week that it issued a Finding of Violation to MidFirst Bank for violations of
General
Alex Cotoia, Regulatory Manager and Compliance Consultant, rejoins us for a timely posting on compliance overkill in this era of aggressive sanctions enforcement. Alex can be reached at acotoia@volkovlaw.com. The uptick in recent sanctions activity caused in large part by the Russian Federation’s unprovoked and unilateral invasion
General
We have all read about the high-profile malicious cyber-attacks and ransomware demands and payments. The Colonial Pipeline case demonstrated how responsive law enforcement can be in tracking down perpetrators and recovering ransom payments. The Treasury Department’s Office of Foreign Asset Control (“OFAC”) has a vested interest in