The Presumption of Innocence Podcast: Episode 45 - The Grit, Grace and Gift of Second Chances
Wicked Coin: The "Fat Leonard" Scandal
Navigating Civil Standing Requirements for Defense Success — RICO Report Podcast
Episode 330 – Halyna Senyk on Anti-Corruption Progress in Ukraine
Managing Corruption Risk in Latin America
The Presumption of Innocence Podcast: Episode 38 - A Blueprint for Compliance: The Fraud Pentagon Theory
Episode 323 - Carlos Villagran Discusses Rebuilding a Corporate Culture After a Crisis
The Presumption of Innocence Podcast: Episode 34 - A Conversation With Jesse Eisinger, Author of 'The Chickenshit Club: Why the Justice Department Fails to Prosecute Executives'
Episode 317 -- A Deep Dive into the Trafigura FCPA Settlement
What's Going on with FCPA?
Episode 316 -- DOJ Announces New Whistleblower Policy
RICO Vicarious Liability — RICO Report Podcast
Episode 313 -- The Coming Criminal Corporate Sanctions Enforcement Storm
RICO Damages — RICO Report Podcast
Corruption, Crime & Compliance: DOJ’s Shifting Approach to Recidivism and Self-Disclosure
Episode 305 -- Deep Dive into SAP FCPA Settlement
AGG Talks: Antitrust and White-Collar Crime Roundup - Developments in the Trump Indictments and Recent Supreme Court Issues
Episode 300 -- Deep Dive into DOJ FCPA Settlement with Two U.K. Reinsurance Companies for Bribery in Ecuador
AGG Talks: Antitrust and White-Collar Crime Roundup - Examining the Latest Updates in the Pending Criminal and Civil Litigation Against Trump
The EU Directive for Combatting Corruption
In its proposed Plea Agreement, the Department of Justice (DOJ) lays out the abject failures of Boeing which led the DOJ to conclude the underlying Deferred Prosecution Agreement (DPA) from 2021 has been breached. The DOJ...more
When it comes to corporate accountability and the often murky waters of compliance, few cases are as illustrative and significant as the ongoing litigation involving Boeing. Since the 737 MAX safety scandal erupted in 2021,...more
Boeing’s Plea Agreement includes two Separate Factual Statements — the January 7, 2021 DPA, which is discussed in a prior blog post, and a factual outline of Boeing’s breach of the original DPA, resulting in the current Plea...more
In probably a move that will surprise no one, the families of the victims of the two Boeing 737 MAX crashes have objected to the Department of Justice’s (DOJ) announced approach to a monitorship for Boeing. Having been so...more
There has not been a company which has had a run of worse publicity in 2024 than Boeing. Unfortunately it has been self-inflicted. I recently participated in a webinar with Sam Silverstein on what Boeing can do to try and...more
The Corporate Transparency Act (CTA), enacted by Congress as part of the Anti-Money Laundering Act of 2020, for the first time under federal law, requires the establishment of a centralized, national beneficial ownership...more
The Department of Justice criminal prosecution of Mark Forkner, chief technical pilot at Boeing responsible for the 737 Max, ended in quick acquittal. DOJ prosecutors suffered an embarrassing loss in an attempt to hold...more
The board of directors (“Board”) of The Boeing Company (“Boeing”) agreed to a staggering $237.5 million settlement of a lawsuit brought by stockholders on behalf of Boeing alleging that the Board and certain executive...more
The crushing aftermath of the tragic 737 MAX scandal is disturbing at the least. Innocent lives were lost because of Boeing’s culture misfires, poor leadership at the management and board level, and an arrogant disregard for...more
In its decision, the Chancery Court methodically analyzed the weaknesses in Boeing’s board processes and its fundamental failure to meet basic Caremark standards in tackling airplane safety issues, particularly after the Lion...more
When I reviewed again the US Department of Justice’s conclusions reached as part of the Boeing criminal investigation, and the Delaware Chancery Court’s decision denying Boeing’s motion to dismiss the shareholder derivative...more
Boeing’s criminal conduct, as described in the settlement papers, centered on two of its 737 MAX Flight Technical Pilots, who deceived the FAA about an important aircraft part called the Maneuvering Characteristics...more
Boeing is still under investigation. A grand jury is investigating potential safety and obstructions allegations. Congressional investigations are continuing....more
Big-Tech/Antitrust Update: the FTC has demanded information from Amazon.com Inc., Apple Inc., Facebook Inc., Microsoft Corp., and Alphabet Inc. regarding acquisitions of small firms over the past 10 years that may have been...more
Credit Suisse’s CEO Tidjane Thiam is out, to be succeeded next week by longtime company vet Thomas Gottstein. Thaim appeared to have ridden out the corporate spying scandal involving a former employee last year, and he had...more
Home speaker maker Sonos has sued Google, accusing the company of “infringing on five of its patents, including technology that lets wireless speakers connect and synchronize with one another.” Sonos had originally partnered...more
You know this has been a big year in FCPA enforcement when DOJ and the SEC announce two FCPA settlements during the usually sleepy week between Christmas and New Years. And what a year it has been – more to follow in my...more
In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international anti-corruption developments from the past month, with links to primary...more
The Embraer FCPA settlement action contains a number of important lessons learned and compliance reminders. In several significant respects, the Embraer case confirms in several areas why proactive compliance programs are...more
After years of investigation, disclosures, and press reports, the Embraer FCPA case finally came to a close. Hopefully, we will not see more of these long-term, seemingly endless investigations. The Justice Department and the...more
Today I continue my exploration of the recently announced Department of Justice (DOJ) and Securities and Exchange Commission (SEC) Foreign Corrupt Practices Act (FCPA) enforcement action with the announcement of the...more