On September 26, 2023, U.S. export enforcement authorities, jointly with enforcement authorities in four allied countries (the Five Eyes), issued additional guidance in order to prevent the diversion of goods in violation of...more
12/7/2023
/ Belarus ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Export Controls ,
Exports ,
Foreign Policy ,
Foreign Relations ,
Foreign Trade Regulations ,
Goods or Services ,
Joint Statements ,
Manufacturers ,
Russia ,
U.S. Commerce Department ,
Ukraine
On October 4, 2023, the U.S. Department of Justice (DOJ) announced a uniform approach for the resolution of voluntary self-disclosure (VSD) of misconduct discovered during M&A due diligence. The Mergers & Acquisitions Safe...more
On the one-year anniversary of the invasion of Ukraine, the Biden administration has announced a series of additional sanction measures targeting Russia. These new sanctions are designed to further isolate Russia from goods...more
3/10/2023
/ Biden Administration ,
Economic Sanctions ,
Entity List ,
Export Controls ,
Foreign Policy ,
Foreign Trade Regulations ,
G7 ,
Manufacturers ,
Military Conflict ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Tariffs ,
U.S. Commerce Department ,
Ukraine
The U.S. Department of Justice (DOJ) recently announced several new policies and programs aimed at incentivizing corporate compliance. These programs underscore the need for companies to investigate, mitigate and resolve...more
On October 7, 2022, the U.S. Department of Commerce announced a series of new export controls designed to curtail China’s access to certain advanced semiconductor chips and technology, integrated circuits, and advanced...more
Last week, the United States Securities and Exchange Commission (SEC) fined 16 Wall Street firms a total of $1.1 billion for recordkeeping violations based on the failure to maintain employees’ electronic communications, such...more
10/6/2022
/ CFTC ,
Civil Monetary Penalty ,
Department of Justice (DOJ) ,
Electronic Communications ,
Enforcement Actions ,
Financial Institutions ,
Financial Services Industry ,
Monaco Memo ,
Recordkeeping Requirements ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act of 1934 ,
Securities Violations
What To Do When The Government Knocks On Your Lab’s Door -
The volume of federal enforcement actions involving laboratories has increased dramatically over the last few years. Not a month seems to pass without a press...more
7/15/2022
/ Clinical Laboratories ,
Coronavirus/COVID-19 ,
Cybersecurity ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Healthcare ,
Hospitals ,
Infectious Diseases ,
Life Sciences ,
Pharmaceutical Industry ,
Price Transparency ,
Virus Testing
Earlier this month, it was announced that Honeywell International, Inc. (Honeywell) had entered into a $13 million administrative settlement with the U.S. government to resolve allegations of export control violations related...more
5/11/2021
/ Aerospace ,
Arms Export Control Act ,
Biden Administration ,
Corporate Counsel ,
Defense Sector ,
Export Controls ,
Failure to Comply ,
Honeywell International ,
ITAR ,
Self-Disclosure Requirements ,
Settlement Agreements
Proposition 65 is the California law that requires warning labels on products sold to California customers that potentially expose users to certain chemicals which may cause a risk of cancer or reproductive harm. ...more
It would be a mistake to think that the $2.9 billion settlement Goldman Sachs Group Inc. has agreed to pay in order to resolve allegations of widespread bribes to government officials in Malaysia and the United Arab Emirates...more
McDonald’s Corporation, a Fortune 500 company and one of the world’s largest fast-food chains, was recently reminded of the value of two basic internal controls: maintaining an anonymous reporting system and conducting an...more
Along with increased news about the spread of COVID-19 across the country, there has been a surge of price gouging allegations and reports of government investigations into that conduct, particularly in the northeast, likely...more
Last week, a jury found a former executive of a French multinational company guilty of violating the Foreign Corrupt Practices Act, money laundering, and conspiracy in connection with alleged bribery in Indonesia....more
11/20/2019
/ Aiding and Abetting ,
Corruption ,
Criminal Conspiracy ,
Criminal Convictions ,
Criminal Liability ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Workers ,
Manufacturers ,
Money Laundering ,
Multinationals ,
Regulatory Violations ,
Subsidiaries ,
White Collar Crimes
Earlier this year, the United States Department of Justice (DOJ) issued new guidance regarding how it evaluates corporate compliance programs in the context of civil and criminal enforcement matters....more
A Brief Overview of the FCPA -
The Foreign Corrupt Practices Act (FCPA) is a federal statute that prohibits United States companies and individuals from bribing foreign government officials in order to gain or retain...more
9/7/2018
/ Alstom ,
Appeals ,
Bribery ,
Corruption ,
Criminal Conspiracy ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Extraterritoriality Rules ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Nationals ,
Foreign Subsidiaries ,
Government Officials ,
Public Contracts ,
Statutory Violations ,
Utilities Sector ,
White Collar Crimes
In the last few months, the United States Department of Justice (DOJ) and the Office of Inspector General (OIG) have obtained over half a billion dollars in settlements and multiple criminal convictions arising from...more
Many business have suffered the misery and frustration of a harshly negative, anonymous online review. That anonymity, critics argue, frees the reviewer from worries about the need for accuracy and, worse yet, encourages the...more
Last week a New York state appeals court recognized that “Facebook users share more intimate personal information through their Facebook accounts than may be revealed through rummaging about one’s home.” Nonetheless, the...more
Last week, the FTC encouraged companies to self-report data breaches with the promise of more likely favorable treatment. The statement comes in a blog post, authored by Mark Eichorn, an Assistant Director in the FTC Bureau...more
Ice cream maker Blue Bell Creameries has found itself in a sticky situation that underscores the importance of a having a comprehensive and robust compliance program, even for companies who do not manufacture consumer...more
Individuals who act quickly can receive a tax break for distributions in 2014 from an Individual Retirement Account (IRA) to a qualified charity. For the past four years, a distribution of up to $100,000 from an IRA paid...more
The named beneficiary of an Individual Retirement Account (IRA) or Roth IRA inherits a golden egg —an asset with uniquely valuable characteristics. In June, however, the United States Supreme Court in Clark v. Rameker issued...more