The Trump Administration is committed to a re-defined objective of fair trade. This will have a significant impact on all businesses, across all operational functions. This is not surprising — for years, the United States...more
4/30/2025
/ Anti-Dumping Duty ,
Countervailing Duties ,
Customs and Border Protection ,
Enforcement Actions ,
Fraud ,
Harmonized Tariff Schedule of the United States (HTSUS) ,
Imports ,
International Trade ,
Penalties ,
Tariffs ,
Trade Relations ,
Trump Administration ,
US Trade Policies
Could your routine data transfers now violate federal law? The DOJ’s new Data Security Program (DSP) targets the flow of U.S. sensitive personal and government data to foreign adversaries — and the clock is ticking. In this...more
How prepared is your organization to handle the evolving landscape of sanctions compliance? In this episode of Corruption, Crime and Compliance, Michael Volkov dives into critical sanctions compliance cases and their...more
The dust is settling and for all the drama surrounding the Trump Administration’s refocus on FCPA enforcement, the picture is becoming a little bit clearer. When cooler heads prevail, it is much easier to pick through the...more
2/14/2025
/ Anti-Corruption ,
Compliance ,
Corporate Governance ,
Department of Justice (DOJ) ,
Diversity and Inclusion Standards (D&I) ,
Enforcement Actions ,
Executive Orders ,
False Claims Act (FCA) ,
Foreign Corrupt Practices Act (FCPA) ,
Regulatory Agenda ,
Regulatory Reform ,
Trump Administration
As we continue through the maze of Executive Orders and new Guidance, which is expected in 180 days, the questions surrounding FCPA enforcement are swirling. In some respects, we have had a preview. It is hard to know what...more
2/12/2025
/ Anti-Corruption ,
Corruption ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
International Emergency Economic Powers Act (IEEPA) ,
National Security ,
OECD ,
Regulatory Agenda ,
Regulatory Freeze ,
RICO ,
White Collar Crimes
In an unprecedented action, the Trump Administration pushed the button and ended FCPA enforcement, at least for 180 days, until new guidance is issued by the Department of Justice. The White House’s announcement seemed to...more
Family International, a Florida real estate company, and its U.S. owner, Roman Sinyavsky, settled with OFAC for $1.07 million for 73 violations of the Russia Sanctions program. In a separate criminal case, Roman Sinyavsky...more
2/5/2025
/ Compliance ,
Corporate Misconduct ,
Criminal Prosecution ,
Economic Sanctions ,
Enforcement Actions ,
Financial Crimes ,
Fines ,
Fraud ,
Guilty Pleas ,
Money Laundering ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
White Collar Crimes
In 2017, when President Trump first took office, big changes were expected in FCPA enforcement. Much of this reflected President Trump’s expressed misgivings on the substance of the FCPA. He was not a big fan of the law and...more
1/28/2025
/ Anti-Corruption ,
Compliance ,
Corporate Governance ,
Corporate Misconduct ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Regulatory Reform ,
Securities and Exchange Commission (SEC) ,
Trump Administration ,
U.S. Treasury
Can the DOJ’s commitment to holding individuals and corporations accountable under the FCPA survive the changing political climate in 2025?
Will the push for innovation in corporate compliance programs be enough to maintain...more
Córdoba Music Group LLC (Córdoba), a manufacturer of musical instruments based in California, has agreed to pay $41,591 to settle its civil liability for violations of sanctions on Iran. On nine occasions, Córdoba shipped...more
1/24/2025
/ Civil Monetary Penalty ,
Compliance ,
Economic Sanctions ,
Enforcement Actions ,
Export Controls ,
International Trade ,
Iran ,
Iran Sanctions ,
Office of Foreign Assets Control (OFAC) ,
Reporting Requirements ,
Risk Management ,
Sanction Violations ,
US Trade Policies ,
Voluntary Disclosure
OFAC means what it says — in more ways than one. In a precedent setting case, OFAC brought its first enforcement action against an individual for violating the Global Magnitsky Sanctions Regulations....more
1/23/2025
/ Anti-Corruption ,
Blocked Person ,
Compliance ,
Economic Sanctions ,
Enforcement Actions ,
Financial Services Industry ,
Financial Transactions ,
Global Magnitsky Act ,
Human Rights ,
Office of Foreign Assets Control (OFAC) ,
Sanction Violations ,
Sanctions ,
SDN List ,
Settlement ,
Statutory Violations ,
U.S. Treasury ,
White Collar Crimes
Enforcement and compliance prognosticators (like myself) continued to push DOJ’s promise to transform sanctions enforcement into the era of “the new FCPA.” While DOJ’s promise to bring about an aggressive corporate...more
1/22/2025
/ Anti-Corruption ,
Compliance ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Export Controls ,
Financial Crimes ,
Foreign Corrupt Practices Act (FCPA) ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
White Collar Crimes
While DOJ did not have an overwhelming FCPA enforcement year, DOJ has devoted significant energy to tweaking its enforcement and compliance policies. These measures were believed to coincide with a number of significant...more
How will your company withstand the heat of aggressive sanctions enforcement? Are you ready for the DOJ’s new priorities and OFAC’s expanding reach in 2025?
In this episode of Corruption, Crime, and Compliance, Michael...more
Criminals can be creative — that is a true statement but essentially FCPA criminals have to embrace a variety of well-established techniques to accomplish a straight-forward goal — steal money from the company to funnel...more
1/16/2025
/ Anti-Corruption ,
Bribery ,
Compliance ,
Corporate Governance ,
Corruption ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Third-Party Risk ,
White Collar Crimes
With the end of the Biden Administration, it is hard to identify a consistent theme relating to FCPA enforcement. On the one hand, the Biden Administration talked a big game, elevating the anti-corruption fight as a national...more
1/16/2025
/ Anti-Corruption ,
Biden Administration ,
Compliance ,
Corporate Misconduct ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Enforcement Statistics ,
Foreign Corrupt Practices Act (FCPA) ,
Penalties ,
Voluntary Disclosure ,
Whistleblowers ,
White Collar Crimes
C.H. Robinson International Inc. (CHR), a Minnesota-based global transportation and logistics company, has agreed to pay $257,690 to settle civil liability for 82 apparent violations of sanctions against Iran and Cuba...more
1/14/2025
/ Acquisition Agreements ,
Civil Monetary Penalty ,
Compliance ,
Corporate Governance ,
Cuba ,
Economic Sanctions ,
Enforcement Actions ,
Foreign Subsidiaries ,
Iran ,
Iran Sanctions ,
Office of Foreign Assets Control (OFAC) ,
Ports ,
Regulatory Requirements ,
Risk Management ,
Sanction Violations ,
Settlement ,
Shipping
Despite a relatively slow year in OFAC sanctions enforcement, OFAC closed 2024 with a string of settlements in five cases, including its second in 2024 against an individual defendant. While OFAC had a slow year, DOJ...more
1/9/2025
/ Anti-Money Laundering ,
Compliance ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Financial Crimes ,
Financial Institutions ,
Iran ,
Iran Sanctions ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Sanction Violations
AAR, a provider of aviation products and services, engaged in two separate bribery schemes. State-owned entities and government agencies permeate the aviation industry. As a result, FCPA risks are embedded in direct...more
1/8/2025
/ Anti-Corruption ,
Aviation Industry ,
Bribery ,
Compliance ,
Corporate Fraud ,
Corruption ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Securities and Exchange Commission (SEC) ,
White Collar Crimes
The Justice Department and the SEC finished 2024 with a coordinated resolution of criminal and civil FCPA charges against AAR Corporation, an Illinois-based provider of aviation products and services. In addition, DOJ...more
In a far-reaching criminal case, in November 2024, the Justice Department unsealed a complex, five-count indictment in the Eastern District of New York charging eight defendants, including Gautam S. Adani, Sagar R. Adani and...more
12/20/2024
/ Bribery ,
Compliance ,
Corruption ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
False Statements ,
Fraud ,
India ,
Indictments ,
Misleading Statements ,
Public Contracts ,
Solar Energy ,
White Collar Crimes
The McKinsey FCPA case follows several other significant cases involving South Africa. ABB and SAP resolved FCPA cases involving bribes in South Africa; on the SEC front, Gartner resolved a bribery case involving South...more
On December 5, 2024, DOJ announced a settlement with McKinsey and Company for $122 million for bribes paid to South African government officials to secure valuable consulting contracts....more
12/18/2024
/ Bribery ,
Compliance ,
Corruption ,
Criminal Investigations ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Guilty Pleas ,
Settlement ,
White Collar Crimes
What happens when a Chief Executive Officer becomes the architect of a global bribery scheme?
In this episode of Corruption, Crime, and Compliance, Michael Volkov delivers an in-depth analysis of the BIT Mining FCPA case —...more
Bit Mining, formerly 500.com, was a doomed company from the beginning, When a CEO orchestrates a bribery scheme with the assistance of other senior executives, shareholders and the public have little chance of ensuring a...more
12/13/2024
/ Bitcoin ,
Bitcoin Mining ,
Bribery ,
C-Suite Executives ,
Compliance ,
Corporate Misconduct ,
Cryptocurrency ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Popular ,
Settlement ,
Statutory Violations