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Books & Records Department of Justice (DOJ) White Collar Crimes

Littler

Robust Action Helps Recidivist Employer Reduce Penalty for Alleged Bribery in South Africa and Indonesia

Littler on

In the first major action of 2024, the Department of Justice (DOJ) announced it had entered into a three-year deferred prosecution agreement (DPA) with a publicly traded global software company for alleged violations of the...more

The Volkov Law Group

WPP, the Largest Global Advertising Group, Settles FCPA Charges with SEC for $19.2 Million (Part I of III)

The Volkov Law Group on

After a long hiatus, the SEC announced a settlement with WPP plc, the world’s largest advertising group, for FCPA violations in India, China, Brazil and Peru for $19.2 million.  The SEC’s resolution charges WPP with...more

The Volkov Law Group

DOJ Hits Beam Suntory with FCPA Settlement for $19.5 Million (Part I of II)

The Volkov Law Group on

Beam Suntory, a global producer and distributor of distilled beverages, settled its FCPA case with DOJ for $19.5 million for bribes paid in India.  The DOJ settlement follows an SEC FCPA settlement for $8 million announced...more

Thomas Fox - Compliance Evangelist

The Herbalife FCPA Enforcement Action: Part 1 – Introduction

Herbalife Nutrition Ltd (Herbalife) recently concluded a long running Foreign Corrupt Practices Act (FCPA) enforcement action with both the Department of Justice (DOJ) and Securities and Exchange Commission (SEC). Herbalife...more

The Volkov Law Group

Herbalife Settles FCPA Charges and Agrees to Pay $123 Million (Part I of III)

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DOJ and the SEC settled concluded its long-pending FCPA investigation of Herbalife Nutrition Ltd (“Herbalife”). ...more

Skadden, Arps, Slate, Meagher & Flom LLP

Ericsson Agrees To Pay Over USD $1 Billion To Settle FCPA Charges

On December 6, 2019, Telefonaktiebolaget LM Ericsson (Ericsson or the Company), resolved long-running investigations by the U.S. Department of Justice (DOJ) and the U.S. Securities and Exchange Commission (SEC) into the...more

Thomas Fox - Compliance Evangelist

Billion Dollar Baby: Ericsson FCPA Enforcement Action – Part 5: Lessons Learned for the Compliance Professional

Last week the Justice Department (DOJ) announced a resolution of the long standing Foreign Corrupt Practices Act (FCPA) enforcement action involving Telefonaktiebolaget LM Ericsson (Ericsson), a multinational networking and...more

Thomas Fox - Compliance Evangelist

Billion Dollar Baby: Ericsson FCPA Enforcement Action - Part 4: The Double Whammy in Penalties

Last week the Justice Department (DOJ) announced a resolution of the long standing Foreign Corrupt Practices Act (FCPA) enforcement action involving Telefonaktiebolaget LM Ericsson (Ericsson), a multinational networking and...more

Thomas Fox - Compliance Evangelist

Billion Dollar Baby: Ericsson FCPA Enforcement Action – Part 3: Internal Control Failures

Last week the Justice Department (DOJ) announced a resolution of the long standing Foreign Corrupt Practices Act (FCPA) enforcement action involving Telefonaktiebolaget LM Ericsson (Ericsson), a multinational networking and...more

The Volkov Law Group

Ericsson’s Pervasive Bribery Conduct: The Toxic Mix of Senior Executive Involvement and Third Party Corruption (Part II of II)

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Ericsson’s FCPA settlement is in the books (not the books and records).  But it casts a significant shadow across the FCPA landscape.  A pervasive and systemic culture of bribery is defined to reflect senior executive...more

Thomas Fox - Compliance Evangelist

Ex-Braskem CEO Indicted on FCPA, AML and Books and Records Charges

Yesterday, the Department of Justice (DOJ) announced three charges against Jose Carlos Grubisich, the former Chief Executive Officer (CEO) of Braskem S.A. (Braskem), a publicly traded Brazilian petrochemical company, for his...more

The Volkov Law Group

Under Armour Under DOJ and SEC Investigation For Revenue Recognition Scheme

The Volkov Law Group on

The Justice Department and the SEC have launched criminal and civil accounting fraud investigations against Under Armour.  The sportswear maker has been suffering a rapid revenue decline over the last few years....more

A&O Shearman

FCPA Digest - Recent Trends and Patterns in the Enforcement of the Foreign Corrupt Practices Act - July 2019

A&O Shearman on

Recent Trends And Patterns In FCPA Enforcement - Although the DOJ and SEC brought a relatively low number of FCPA enforcement actions in the first half of 2019, an unusually large portion of those enforcement actions...more

Troutman Pepper

Enhanced Anti-Corruption Scrutiny in Construction Industry

Troutman Pepper on

Bribery and corruption have long plagued the construction industry, particularly in emerging markets in Latin America, Eastern Europe, the Middle East and Asia-Pacific. ...more

The Volkov Law Group

Cognizant Technology Pays $25 Million for FCPA Violations and Earns Declination — Two Executives are Indicted for Criminal FCPA...

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In the first corporate FCPA action of 2019, Cognizant Technology Solutions Company settled its long-running FCPA case, agreeing to pay the SEC $25 million....more

The Volkov Law Group

Eletrobras Settles SEC FCPA & Bid-Rigging Enforcement Action for $2.5 Million

The Volkov Law Group on

In a December 2018 enforcement settlement, the SEC and Brazil’s Centrais Elétricas Brasileiras S.A. (“Eletrobras”) agreed to violating books and records and internal accounting controls requirements and paid a $2.5 million...more

Holland & Knight LLP

DOJ Issues New Guidance on Necessity and Selection of Corporate Monitors

Holland & Knight LLP on

• Assistant Attorney General Brian A. Benczkowski's recent Memorandum on "Selection of Monitors in Criminal Division Matters" provides new direction to U.S. Department of Justice (DOJ) prosecutors regarding when to require...more

The Volkov Law Group

Dun and Bradstreet Pays $9 Million for FCPA Violations in China

The Volkov Law Group on

After a lengthy investigation, Dun and Bradstreet (D&B) settled an FCPA enforcement action with the Securities and Exchange Commission for $9 million. ...more

Thomas Fox - Compliance Evangelist

Panasonic FCPA Enforcement Action: Part II – The Bribery Schemes

We continue our exploration of the Foreign Corrupt Practices Act (FCPA) enforcement action involving Panasonic Avionics Corporation (PAC) and its parent Panasonic Corporation (Panasonic). Today, I want to review the bribery...more

Thomas Fox - Compliance Evangelist

A ‘Most Daring Act’ and the SQM FCPA Enforcement Action – Part I

A most “daring act” seems to be a good way to introduce a multi-part look at the recent Foreign Corrupt Practices Act (FCPA) enforcement action involving the Chilean chemicals and mining company Sociedad Química y Minera de...more

The Volkov Law Group

FCPA Recidivists: Zimmer Biomet (Part I of II)

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The drug and medical device industries have been taking it on the FCPA chin for years. The risk factors in the international marketplace are significant – healthcare professionals are normally government employees; government...more

Thomas Fox - Compliance Evangelist

A Company Must Do Compliance – The Mondelez FCPA Enforcement Action

In almost every Foreign Corrupt Practices Act (FCPA) enforcement action, there are nuggets to be gleaned for any Chief Compliance Officer (CCO) or compliance practitioner. All one has to do is look for them. Back in 2012,...more

Thomas Fox - Compliance Evangelist

Embraer FCPA Enforcement Action, Part I

The Department of Justice (DOJ) and Securities and Exchange Commission (SEC) continued their stunning 2016 run of Foreign Corrupt Practices Act (FCPA) decisions with the announcement of the resolution of the Embraer SA...more

The Volkov Law Group

Och-Ziff: Accountability and Internal Controls (Part IV)

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There are a number of important lessons from the Och-Ziff enforcement action, some of which are related to the private equity and hedge fund industry and some of which apply across all businesses....more

The Volkov Law Group

FCPA Enforcement Ramping Up Against Private Equity and Hedge Funds (Part III)

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The Och-Ziff settlement has now set the stage for the Justice Department and the SEC to focus its enforcement eye on the private equity and hedge fund industry. The Och-Ziff action was initiated in response to the SEC’s...more

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