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Fasten Your Seatbelt: An Important Message on Proactive Compliance

I’m old enough to remember when seat belts were optional. And I remember people up in arms when seatbelt laws first passed. But now, my young adult children and their friends simply get in the car and buckle up without...more

A New Year’s Resolution for Companies involved in Defense Business

On December 5, 2022, the Department of State, Directorate of Defense Trade Controls (“DDTC”) issued new Compliance Program Guidelines, “intended to provide an overview of an effective compliance program and an introduction to...more

Russian Sanctions Update: Five Months into the War in Ukraine

It’s been five months since Russia invaded the Ukraine, and the United States has imposed a succession of increasingly severe economic sanctions on Russia and Belarus. A recent study published by Jeffrey Sonnenfeld, a...more

OFAC Enforcement Action: Double Check Your Screening Tools

Some may dismiss OFAC’s recent announcement last week that it issued a Finding of Violation to MidFirst Bank for violations of the Weapons of Mass Destruction Proliferators sanctions regulations as insignificant because OFAC...more

Putin’s Puppets Pick on Peppa Pig: Intellectual property rights are collateral damage in the economic war between Russia and the...

As we’ve reported elsewhere in our blog, the U.S., EU, and other nations recently have enacted significant economic sanctions against Russian individuals and entities in response to Russia’s invasion of Ukraine. Russia is...more

2021 False Claims Act Year in Review: Judicial and Congressional Developments (II of II)

As for the Judiciary, the U.S. Supreme Court did not issue any relevant decisions nor grant certiorari in any notable FCA cases in FY21. To the contrary, they denied petitions to review appellate cases of potential...more

2021 False Claims Act Year in Review: Enforcement Statistics (Part I of II)

Worth the Wait? DOJ finally released its Fraud Statistics for FY 2021 and announced the “second largest amount recorded” since 1986: FCPA Settlement and judgment exceed $5.6 billion...more

False Claims Act 2020 Year in Review: The FCA “Has Never Been More Important Than it is Right Now”

$1.9 trillion dollars of federal spending on the horizon. That’s right, immediately following his inauguration in 2021, President Biden proposed a $1.9 trillion stimulus plan to help recover from the COVID-19 pandemic....more

Attention U.S. Exporters to Hong Kong: Have you Reviewed Your Export Licenses and Trade Compliance Program to Account for Recent...

Until recently, the U.S. government treated Hong Kong and China as two separate destinations for export control purposes and in many cases provided Hong Kong with preferential treatment....more

Herbalife FCPA Settlement is An Important Reminder: Global Companies Need to Focus on Foreign Government Touchpoints

As we look past the Herbalife FCPA settlement with DOJ and the SEC for $123 million to resolve FCPA bribery and books and records violations, we are reminded of the variety of foreign government touchpoints and FCPA risks....more

Are Compliance Officers “Essential”?

In these challenging times, when governments around the world are asking all “non-essential” workers to stay home, and companies are struggling with business interruptions and difficult decisions regarding pay-cuts, layoffs...more

False Claims Act 2019 Year in Review

Jessica Sanderson, Of Counsel at The Volkov Law Group rejoins us for her annual review of False Claims Act enforcement. 2020 marks the 150th anniversary of the Department of Justice (“DOJ”), and it unwrapped a nice gift:...more

Compliance Messaging: Need a Reason? ‘Tis the Season!

As the holidays quickly approach, consider sending a message from the Board or senior management reminding employees about your gift and hospitality policy....more

OFAC’s New §501.604 Reporting Requirement: A Small Change with a Big Impact

On June 21, 2019, OFAC changed its requirements for reporting on blocked or rejected transactions under 31 C.F.R. §501.604.  With little fanfare, the interim rule published in the Federal Register greatly expands the...more

U.S. Entities Engaged in M&A Transactions Beware; OFAC Highlights the “Unique Sanctions Risks” Posed by Foreign Acquisitions

On June 13, 2019, OFAC announced a settlement with Expedia Group, Inc. for violations of the Cuban Assets Control Regulations (“CACR”).  (Available here).  Expedia’s foreign subsidiaries assisted more than 2,200 individuals...more

Report from SEC Conference: Compliance, Cooperation and Culture

On Friday May 3, 2019, I attended the Rocky Mountain Securities Conference in Denver and heard from a number of regulators and industry experts, including SEC Commissioner Hester Peirce. ...more

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