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Bass, Berry & Sims PLC

International Trade Enforcement Roundup – September 2024

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What happened? On September 10, the SEC announced that John Deere agreed to pay almost $10 million to resolve allegations it had violated the FCPA. The SEC alleged that Wirtgen Thailand, an indirect subsidiary of John Deere,...more

The Volkov Law Group

Sanctions Compliance: Understanding the Red Lines of Enforcement (Part I of II)

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In this new era of aggressive sanctions enforcement, companies have to understand the red lines that define where criminal and civil enforcement risk increase.  In contrast to the history of FCPA enforcement, DOJ and OFAC...more

The Volkov Law Group

Congress Extends Sanctions Statute of Limitations And Addresses Other National Security Issues

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On April 24, 2024, President Biden signed into law a sweeping national security legislative package that included the 21st Century Peace Through Strength Act, which includes measures to promote sanctions and export controls...more

The Volkov Law Group

The Same Old Song with a Different Meaning — Third-Party Risks and Sanctions Compliance (Part I of IV)

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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). So, how does that relate to third-party risks?  Well,...more

The Volkov Law Group

DOJ and OFAC Sanctions and Export Control Detection Strategies

The Volkov Law Group on

In this new aggressive era of sanctions and export controls enforcement, companies need to understand the potential risks that DOJ and/or OFAC may identify a company for sanctions investigation....more

Wiley Rein LLP

Congressman Henry Cuellar’s Federal Charges Include Acting as a Foreign Agent

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Representative Henry Cuellar (D-TX) and his wife, Imelda Cuellar, are facing federal charges of bribery, money laundering, and violations of the ban against public officials serving as foreign agents required to register...more

Mayer Brown

US DOJ’s National Security Division Updates Enforcement Policy for Criminal Sanctions and Export Control Violations with New Focus...

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On March 7, 2024, the US Department of Justice’s National Security Division (NSD) released a revised Voluntary Self-Disclosure (VSD) Policy (the “VSD Policy”). The VSD Policy substantially tracks the language of the previous...more

Stinson LLP

The Corporate Transparency Act Found Unconstitutional, Now What?

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On Friday March 1, 2024, Judge Liles C. Burke of the U.S. District Court for the Northern District of Alabama ruled that the Corporate Transparency Act (CTA) is an unconstitutional overreach of Congress's enumerated powers in...more

The Volkov Law Group

Preparing for the Storm — Effective Compliance in the New Sanctions Era (Part II of II)

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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...more

The Volkov Law Group

2023 Sanctions Year in Review and Predictions

The Volkov Law Group on

As always, I tend to repeat myself.  However, one important point needs to be repeated — DOJ is in the midst of launching an aggressive sanctions and export control program against corporations and individuals.  DOJ has...more

The Volkov Law Group

U.S. Government Charges Parties with Violating U.S. Sanctions and Export Control Laws

The Volkov Law Group on

As we have repeatedly noted in the context of other blog posts and webinars in which various representatives of The Volkov Law Group have participated, the violation of existing U.S. sanctions and export control regulations...more

The Volkov Law Group

BIS and FinCEN Release Joint Notice Concerning Global Export Control Evasion

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On November 6, 2023, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) and the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) released a new joint notice concerning...more

The Volkov Law Group

DOJ Resolves First Corporate Sanctions Case Involving Iran Sanctions Program

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The Justice Department has touted the upcoming wave of corporate prosecutions for criminal sanctions violation as the era of “The New FCPA.” DOJ’s reference is intended to communicate a strong message – companies are going to...more

The Volkov Law Group

Justice, Commerce and Treasury Departments Issue Comprehensive Tri-Party Voluntary Disclosure Guidelines for Sanctions and Export...

The Volkov Law Group on

In another significant step notifying global businesses of the new realities – companies are about to face aggressive coordinated criminal and civil prosecutions for sanctions and export control violations.  The last piece in...more

The Volkov Law Group

Commerce, Justice, State and Treasury Issue Unprecedented Joint Advisory Concerning Iranian UAV Procurement Activities

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In a relatively rare move for four (4) Cabinet-level Departments, the U.S. Departments of Commerce, Justice, State and Treasury issued an advisory notice on June 9, 2023,  aimed specifically at reminding industry of their...more

The Volkov Law Group

Corporate Crime and National Security – The Confluence of Prosecution and Foreign Policy (Part I of III)

The Volkov Law Group on

To restate the obvious – DOJ has prioritized prosecution of national security crimes.  For the business world, every company touches the international economy.  Even a domestic company might sell products or services outside...more

Wilson Sonsini Goodrich & Rosati

OFAC Penalizes Another Crypto Asset Company for Sanctions Violations

In keeping with its recent focus on the crypto asset industry, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced an agreement last week with crypto asset trading platform Poloniex, LLC...more

The Volkov Law Group

DOJ Flexes Enforcement Muscle to Target Viktor Vekselberg, a Russian Oligarch and Co-Conspirator Assisting in Evasion of Russia...

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I am sticking with my 2023 prediction – DOJ is committed to aggressive enforcement of the Russia sanctions.  Most of its efforts to date have been directed against Russian Oligarchs and significant evaders who are moving...more

The Volkov Law Group

Sanctions Enforcement: “The New FCPA”

The Volkov Law Group on

Hold onto your hats – while we are on the cusp of more FCPA enforcement actions, the Justice Department and OFAC are gearing up for real and significant sanctions enforcement actions.  The dye is cast, so here we go. ...more

A&O Shearman

Sanctions Round Up: First Quarter 2022

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The world’s response to Russia’s invasion of Ukraine dominated the first quarter of 2022, as the US and its international partners coordinated efforts to impose unprecedented sanctions designed to isolate the Russian...more

The Volkov Law Group

DOJ Charges Television Producer for Violating Crimea-Related Sanctions Program

The Volkov Law Group on

The U.S. Attorney’s Office for the Southern Direct of New York recently announced the indictment of Jack Hanick, a United States citizen, of violating the U.S. sanctions against Russia and false statements in connection with...more

BakerHostetler

New Key Developments in Response to Russia's Invasion of Ukraine

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The United States and the European Union imposed additional sanctions this week in response to the Russian Federation’s invasion of Ukraine and the United States announced its intention to make sanctions enforcement a...more

Baker Donelson

U.S. Sanctions on Russia and Belarus Increase; Commerce Targets Energy Extraction Equipment; Justice Launches Enforcement Task...

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In our previous alert, we discussed the U.S. implementation of significant sanctions and export controls on Russia which will severely impact business transactions with Russian entities. The U.S. and its allies continue to...more

The Volkov Law Group

DOJ Enforcement and Compliance with the New Russian Sanctions

The Volkov Law Group on

The Department of Justice has announced its plan to aggressively enforce the new Russia Sanctions Program.  In response to the dire humanitarian situation in the Ukraine, DOJ took two significant actions – creation of the...more

Torres Trade Law, PLLC

Trade Enforcement Digest - January 2022

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Civil and criminal penalties levied against U.S. companies for trade violations are just the beginning of the potential unforeseen costs of doing business in the global marketplace. What cannot be quantified are the countless...more

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