News & Analysis as of

Ukraine Anti-Corruption

American Conference Institute (ACI)

FCPA, Export Controls, and Sanctions Enforcement: Adjusting Compliance Strategies for the New Normal

As the interplay between export controls, trade sanctions, and anticorruption enforcement continues to intensify, multinational companies must remain vigilant in ensuring that their compliance programs address the many...more

The Volkov Law Group

Episode 330 – Halyna Senyk on Anti-Corruption Progress in Ukraine

The Volkov Law Group on

Listen to this conversation between Michael Volkov and Halyna Senyk in which they focus on Ukraine's anti-corruption efforts amidst the backdrop of its ongoing war with Russia. Halyna Senyk, an expert from the CEELI...more

Ballard Spahr LLP

The American Front in Russia’s War on Ukraine: DOJ’s “Task Force KleptoCapture” Continues Focus on Operations of Sanctioned...

Ballard Spahr LLP on

We previously have blogged on actions taken by the DOJ’s “Task Force KleptoCapture,” an interagency law enforcement task force with a mandate to target sanctioned Russian and pro-Russian oligarchs. While explicitly launched...more

The Volkov Law Group

DOJ Repeats Warnings on Aggressive Criminal Enforcement of Sanctions and Export Controls

The Volkov Law Group on

As everyone knows, I tend to repeat myself — DOJ does as well.  Over the past year, DOJ has warned global companies — over and over — about the coming criminal enforcement storm against companies for sanctions and export...more

Kohn, Kohn & Colapinto LLP

The Kleptocracy Asset Recovery Rewards Program Is Woefully Inadequate

On December 6, 2021, the Biden administration declared the fight against corruption a core U.S. national security interest. A part of the administration’s “Strategy on Countering Corruption” was the establishment of the...more

Cadwalader, Wickersham & Taft LLP

Tri-Seal Compliance Note Warns of Sanctions Evasion

On March 2, the Department of Commerce, Department of Justice, and Department of the Treasury issued a Tri-Seal Compliance Note warning companies to be vigilant for Russia-related sanctions evasion. The Note sets forth a...more

The Volkov Law Group

DOJ, and Departments of Commerce and Treasury Issue Joint Compliance Note on Evasion of Russia Sanctions and Export Controls

The Volkov Law Group on

As we have noted on numerous occasions, the U.S. Russia Sanctions and Export Control Program is unprecedented and a compliance challenge for all organizations. In another unprecedented action, the Justice Department and the...more

The Volkov Law Group

DOJ & OFAC Sanctions Predictions for 2023

The Volkov Law Group on

Trade compliance is the new hot field.  Companies are catching up with trade compliance in response to the global sanctions regimes put in place to cripple Russia.  The United States, its allies and partners have implemented...more

The Volkov Law Group

DOJ Promoting Enforcement and Compliance Message

The Volkov Law Group on

Contrary to the often-repeated narrative, the Justice Department is transparent about its enforcement plans and compliance expectations.  Since the issuance of the FCPA Guidance in 2012, DOJ has continued to provide guidance...more

Thomas Fox - Compliance Evangelist

FCPA Compliance Report - Mike DeBernardis on Compliance Developments from Q1 2022

In this episode of the FCPA Compliance Report, I welcome back Mike DeBernardis, a partner at Hughes Hubbard, about some of the key developments in ethics compliance and FCPA from Q1 2022. Key areas we discuss on this podcast...more

K2 Integrity

[Webinar] Sanctions Against Russia: Sanctions in Action with K2 Integrity and C4ADS - June 8th, 10:30 am - 11:30 am ET

K2 Integrity on

In this webinar, experts from K2 Integrity, C4ADS, and the Anti-Corruption Action Centre will discuss the current Russian sanctions environment, the ways data is being used to identify and track assets of sanctions targets,...more

The Volkov Law Group

Responding to Supply Chain Glitches and Increased Bribery Risks

The Volkov Law Group on

The evolution in the global economy is raising challenges for anti-corruption compliance.  In response to economic dislocations and disruptions stemming from the COVID-19 pandemic and Russian invasion of Ukraine, businesses...more

Proskauer - Corporate Defense and Disputes

SEC Issues New Guidance Regarding Russia Sanctions and Public Company Disclosures

In response to Russian President Vladimir Putin’s decision to invade Ukraine in February, the U.S. government announced sweeping sanctions against Russia. As the conflict nears the three-month mark, businesses around the...more

Bracewell LLP

Sanctions and Cyber and Crypto, Oh My: The Convergence of Emerging Regulatory and Enforcement Risks Requires Nimble Responses...

Bracewell LLP on

At a sanctions conference held in Washington D.C. on May 5, government officials, practitioners and corporations highlighted the government’s broadening focus on anti-corruption enforcement, across more traditionally siloed...more

Cadwalader, Wickersham & Taft LLP

In Depth: President Biden Proposes New Administrative Forfeiture Process and Other Legislative Changes to Address Ukraine Crisis

Alongside the slew of new sanctions imposed in response to Russia’s invasion of Ukraine, the Biden administration also has been laying the groundwork to maximize the impact of those sanctions. Just days after Russian military...more

Dechert LLP

Sanctions are “the New FCPA”: A Heightened Focus for DOJ Enforcement

Dechert LLP on

At a New York City Bar Association event on April 27, Deputy Attorney General Lisa Monaco described economic sanctions as “the new FCPA.” Her characterization should put corporate compliance departments on notice. ...more

Orrick, Herrington & Sutcliffe LLP

Employers to the Rescue? Potential Compliance Risks When Helping Male Employees Leave Ukraine

Companies seeking to help their Ukrainian employees safely exit Ukraine should be aware of potential risks related to the Foreign Corrupt Practices Act (FCPA) and other U.S. laws and regulations. Following Russia’s invasion...more

Manatt, Phelps & Phillips, LLP

U.S. Economic Sanctions Against Russia Grow Amid the Ukraine Crisis: What Businesses Need to Know (UPDATED)

Originally Published: February 25, 2022 – Updated: March 25, 2022 - U.S. economic sanctions against Russian interests have been building in response to the developing situation between the Russian Federation and Ukraine. ...more

Cadwalader, Wickersham & Taft LLP

Measures Against Russia (Only)? UK Economic Crime (Transparency and Enforcement) Act 2022

Rushed through the Parliament in response to Russia’s invasion of Ukraine, the new Economic Crime (Transparency and Enforcement) Act (the “Act”) received Royal Assent on 15 March 2022....more

Cadwalader, Wickersham & Taft LLP

Russia Sanctions Update: Lux Edition

As the conflict in Ukraine grinds on, sanctions against Russia have continued to tighten. Since we published our Clients & Friends Memo last week, available here, President Biden issued Executive Order (“EO”) 14068 of March...more

Manatt, Phelps & Phillips, LLP

U.S. Economic Sanctions Against Russia Grow Amid the Ukraine Crisis: What Businesses Need to Know (UPDATED)

Originally Published: February 25, 2022 – Updated: March 15, 2022 U.S. economic sanctions against Russian interests have been building in response to the developing situation between the Russian Federation and Ukraine....more

Proskauer - The Capital Commitment

Economic Sanctions and Asset Seizures: An Important Focus for the Biden Administration

Sanctions continue to be a dynamic area of regulation and enforcement. In its first year, the Biden Administration has already undertaken a number of different sanctions initiatives. The three examples below highlight the...more

Proskauer - The Capital Commitment

DOJ Task Force KleptoCapture to Target Russian Oligarchs

Over the past week, the U.S., UK, and EU imposed sweeping sanctions rolled out by the US, in response to Russia’s invasion of Ukraine, outlined here. Also last week, the Department of Justice announced the launch of Task...more

The Volkov Law Group

2019 OFAC Sanctions Enforcement Review (Part I of II)

The Volkov Law Group on

While DOJ had its biggest year in FCPA enforcement, OFAC quietly had a record year in enforcement.  OFAC collected approximately $1.28 billion (yes, with a B) in 26 separate enforcement actions.  That is quite an increase...more

The Volkov Law Group

Apollo Aviation Group Pays $210k to OFAC for Violations of Sudanese Sanctions Program

The Volkov Law Group on

Apollo Aviation Group, now Carlyle Aviation Partners, agreed to pay OFAC $210,600 for 12 violations of the Sudanese Sanctions Program.  Carlyle acquired Apollo in December 2018, and Carlyle was not involved in the...more

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