News & Analysis as of

Bribery Och-Ziff

The Volkov Law Group

Criminal Enforcement Against Senior Executives: The Fish Rots from the Head

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The compliance community is well aware of the risks in the C-Suite. As you move up the corporate ladder, the level of risk from executive misconduct increases. A rotten executive can quickly bring down a company, destroy...more

Hogan Lovells

Top bribery and corruption developments in 2017 for ADG companies

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In recent years, U.S. and Western European military spending has decreased as military spending in other parts of the world has risen. As a result, aerospace, defense and government services (ADG) companies increasingly rely...more

The Volkov Law Group

SEC Snares Two “Masterminds” Behind Och-Ziff Bribery Scheme

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The SEC recently filed a lengthy civil complaint against two Och-Ziff executives: Michael Cohen, who headed Och-Ziff’s European office, and Vanja Barros, an executive responsible for Africa-related transactions, charging them...more

The Volkov Law Group

Badda Bing, Badda Boom!! — DOJ and SEC Make 2016 a Record Year for FCPA Enforcement (Part I of III)

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We begin the New Year with a three-part series on the FCPA: (1) A review of FCPA enforcement in 2016; (2) Trends from 2016 FCPA enforcement; and (3) Predictions for FCPA enforcement in 2017....more

K2 Integrity

2016 Anti-Corruption Review: What Happened?

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Bribery and corruption remained a prominent fixture of media headlines throughout 2016, competing with the UK referendum on membership of the European Union, the Panama Papers leaks, and the continued activity of terrorist...more

The Volkov Law Group

DOJ and SEC Raising the Stakes on Third Party Risk Management

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If you review the last ten years of FCPA enforcement, the unmistakable pattern is rising expectations with regard to corporate compliance programs, particularly with regard to third party due diligence and risk management....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

The Volkov Law Group

Och-Ziff Failures in Due Diligence and Transaction Compliance (Part II)

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The Och-Ziff enforcement action is replete with examples of failures in due diligence and transaction monitoring compliance. Och-Ziff’s bribery schemes were elaborate and intricate and involved complex transactions,...more

King & Spalding

Major FCPA Enforcement Action Against Nation’s Largest Publicly Traded Hedge Fund

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In one of the largest FCPA settlements in history, hedge fund Och-Ziff Capital Management Group LLC (“Och-Ziff”) recently resolved a long-running government inquiry by agreeing to $413 million in financial penalties and a...more

The Volkov Law Group

DOJ and SEC Deliver Body Blow to Private Equity and Hedge Funds: Och-Ziff Settles FCPA Violations for $412 Million (Part I)

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The Justice Department and the Securities Exchange Commission delivered a powerful FCPA enforcement message to private equity and hedge funds. Och-Ziff settled with the DOJ and SEC for total penalties of $412 million....more

Troutman Pepper

Lessons Learned from the FCPA Pilot Program's First Six Months

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The guidance issued by the DOJ in connection with the Pilot Program and recent declinations state that disclosure, remediation and cooperation are essential to any favorable resolution with the government. Six months...more

Robins Kaplan LLP

Your daily dose of financial news - The Brief – 9.30.16

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NY hedge fund Och-Ziff has agreed to pay a $413 million fine as part of a deferred-prosecution agreement with US regulators over allegations that it was involved in the payment of more than $100 million in bribes to African...more

The Volkov Law Group

Private Equity and the Och-Ziff Enforcement Action

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Since 2010, the Justice Department and the SEC have been “investigating” a number of private equity and hedge funds for FCPA violations. The launch of the inquiries was a big deal with lots of fanfare and focus on private...more

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