In his semi-annual report to Congress, Michael K. Atkinson, the intelligence community’s inspector general, expressed “hope that recent events will not have a chilling effect on the willingness of individuals within the Intelligence Community to continue to shed light on suspected fraud, waste, abuse, or malfeasance in an authorized manner.”
In an article published in Corporate Counsel November 27, Kristina Arianina explains the significance of whistleblower protections in any effective compliance function and discusses the effect the Ukraine whistleblower coverage may have on potential workplace whistleblowers. To minimize any potential chilling effect of this coverage, Kristina encourages companies to reaffirm their appreciation for whistleblowers and commitment to non-retaliation against bona fide employee complaints.
A Red Notice allows for detention of an international fugitive. But the practice has been criticized for abuse. In response, a bipartisan group of Congresspersons have introduced the Transnational Repression Accountability and Prevention Act (“the TRAP Act”). This reform legislation, if enacted, will affect politically-motivated Red Notices and enforcement of them around the world.
With day four of public hearings in the President Trump’s impeachment proceedings, Ukraine is on everyone’s mind. In his public testimony on November 19, 2019, Lieutenant Colonel Vindman mentioned several of Ukraine’s anti-corruption efforts, including the establishment of High Anti-Corruption Court. For the most part, however, consistent with the origin of the impeachment inquiry, the focus has been more on the United States than Ukraine.
In an earlier post, 
The Securities and Exchange Commission (“SEC”) recently penalized a public company for violating U.S. economic sanctions. The violation cited the “books and records” and “internal controls” provisions of Securities Exchange Act of 1934 (the “Exchange Act”). With this unprecedented action, the SEC has put companies on notice that the Department of Justice (the “DOJ”) and the Office of Foreign Assets Control (“OFAC”) are not the only sanctions enforcers in Washington.
In an earlier post, 
Malicious actors want to take your data. When they have it, they will make you pay to get it back. Learn about ransomware and how to prepare against it with this informative and practical 
Ask the bank that just paid the SEC more than $ 6 million for failing to adequately train its Asia Pacific Region (APAC) personnel on antibribery with respect to hiring practices. The bank had policies against hiring personnel in exchange for business, but, according to the SEC’s order, the company “failed to effectively train APAC employees or monitor their compliance with those policies…. APAC bankers and compliance personnel lacked familiarity with and understanding of [the company’s] anti-bribery and corruption policies, particularly as those policies relate to hiring.” SEC Order in Administrative Proceeding File No. 3-19537. 