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The Volkov Law Group

Deep Dive into Proposed Boeing Plea Agreement (Part II of III)

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DOJ and Boeing have entered into a proposed plea agreement that will require judicial scrutiny and determinations of the public interest and the victims’ rights under the Crime Victims’ Rights Act, 18 U.S.C. § 3771 [“CVRA”]. ...more

Thomas Fox - Compliance Evangelist

The Proposed Boeing Deal: Part 1 – The Monitorship and Meeting Victims’ Families

The Department of Justice (DOJ) has filed its Plea Agreement in the wake of the Boeing guilty plea. Due to Boeing’s legal challenges, some probation conditions have been imposed to ensure the company adheres to enhanced...more

Thomas Fox - Compliance Evangelist

The DOJ Boeing Conundrum

The Department of Justice (DOJ) is currently in a conundrum over its Deferred Prosecution Agreement (DPA) for the Boeing 737 Max crashes. Understanding the implications of the DOJ’s upcoming decision on whether to prosecute...more

Troutman Pepper

Navigating Employment and Separation Agreements: Lessons From Al Pacino's Serpico — Hiring to Firing Podcast

Troutman Pepper on

In this episode of the Hiring to Firing Podcast, Partners Tracey Diamond and Evan Gibbs, along with fellow Partners Sheri Adler and Mary Weeks, chat about the ultimate whistleblower — police officer Frank Serpico — and the...more

Thomas Fox - Compliance Evangelist

SEC, Solar Winds and Compliance

The recent SEC lawsuit against SolarWinds Corp and its CISO, Tim Brown, following the 2020 data breach, has brought the issue of executive liability in cybersecurity disclosures to the forefront. This case sheds light on the...more

Thomas Fox - Compliance Evangelist

Albemarle FCPA Enforcement Action: Part 3 – The Comeback

Last week, Albemarle Corporation (Albemarle), agreed to pay more than $218 million to resolve investigations by the U.S. Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) into violations of the...more

The Volkov Law Group

Episode 285 -- The Importance of a Consequence Management System

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The Department of Justice has laid down a marker – companies would be smart to understand the significant change in ethics and compliance program expectation.  Companies that ignore this new landscape are gambling with their...more

Akin Gump Strauss Hauer & Feld LLP

Federal Agency Settlements with Wells Fargo Illustrate Sanctions Risks Involving IT Systems

Key Points - On March 30, 2023, OFAC announced a settlement agreement with Wells Fargo for 124 apparent violations of three different sanctions programs (Iran, Syria and Sudan), all related to a legacy Wachovia Bank...more

The Volkov Law Group

Wells Fargo Fumbles Sanctions Compliance Demonstrating An Absence of Culture of Compliance (Part II of II)

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Not that I am a glutton for punishment, but I always find enforcement actions to supply a number of valuable lessons learned. There are always instructive nuggets of information, opportunities missed, and root causes that...more

The Volkov Law Group

Carrie Tolstedt, former Wells Fargo Community Banking Head, Agrees to Plead Guilty and Pay a $17 Million Fine for Obstruction of...

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If there ever is an example of a rotten corporate culture, Wells Fargo sits at the head of the class.  Since Wells Fargo’s sales pressure scandal, Wells Fargo has continued to suffer from a string of scandals and misconduct. ...more

The Volkov Law Group

Lessons Learned from Ericsson’s DPA Breach: An Internal Investigation Nightmare (Part III of III)

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This is not your typical FCPA enforcement action Lessons Learned column.  Instead, Ericsson’s breach of its DPA presents a laundry list of internal investigation errors – as a practitioner in this area, this is the nightmare...more

NAVEX

The Whistleblower Landscape – Reporting Trend Changes May Compel Organizations to Reassess Their Programs

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Until recently, trends in whistleblower reports and behavior seemed to only break through into the news cycle when an extraordinary story made it into mainstream headlines. Now, reports of whistleblower actions and payouts...more

Thomas Fox - Compliance Evangelist

Corporate Case Management in the Era of the DoJ’s Monaco Memo: Speak Up Culture

Welcome to a special five-part podcast series, entitled Corporate Case Management in the Era of the DoJ’s Monaco Memo, sponsored by i-Sight Software Solutions (i-Sight). Over this series, Jakub Ficner, Director of Partnership...more

Orrick, Herrington & Sutcliffe LLP

Enforcement Uptick & Individual Accountability: Here’s What to Know from DOJ’s Updates to Enforcement Policies

The Department of Justice (“DOJ” or the “Department”)’s signals that it is doubling down on corporate criminal enforcement, including focusing on individual accountability, deserve close attention. The updates, announced by...more

Foley Hoag LLP - White Collar Law &...

DOJ Updates Policies on Corporate Ethics and Compliance

Last week, Deputy Attorney General Lisa O. Monaco delivered remarks on corporate criminal enforcement, announcing revisions to DOJ’s policies for addressing corporate ethics and compliance matters. These changes reflect an...more

Society of Corporate Compliance and Ethics...

[Event] Regional Compliance & Ethics Conference - November 11th, Dubai, United Arab Emirates

Looking for compliance training and networking in your area? SCCE’s Regional Compliance & Ethics Conferences offer practitioners convenient, local compliance training, including updates on the latest news in regulatory...more

NAVEX

Another Reminder About a Commitment to Compliance

NAVEX on

The U.S. Justice Department has long said (and compliance officers have said it too) that a culture of compliance is what matters in regulatory enforcement actions, and can pay dividends in the form of smaller monetary...more

Society of Corporate Compliance and Ethics...

[Event] Regional Compliance & Ethics Conference - September 2nd, São Paulo, Brazil

Looking for compliance training and networking in your area? SCCE’s Regional Compliance & Ethics Conferences offer practitioners convenient, local compliance training, including updates on the latest news in regulatory...more

The Volkov Law Group

Stericycle DOJ and SEC FCPA Settlement: Lessons Learned (Part III of III)

The Volkov Law Group on

The Stericycle FCPA case is yet another example of a complete culture and compliance breakdown.  As I often repeat myself, there is no more important control than an ethical culture.  When a culture veers into the unethical...more

Society of Corporate Compliance and Ethics...

[Event] Regional Compliance & Ethics Conference - March 28th, Phoenix, AZ

Looking for compliance training and networking in your area? SCCE’s Regional Compliance & Ethics Conferences offer practitioners convenient, local compliance training, including updates on the latest news in regulatory...more

Thomas Fox - Compliance Evangelist

FCPA Compliance Report - James Koukios on the Monaco Speech

In this episode of the FCPA Compliance Report, I am joined by fan-favourite James Koukios, a partner at Morrison and Foerster, and we take a deep dive into the Lisa Monaco speech from October and related remarks from other...more

Jenner & Block

Anti-Corruption Enforcement - 2021 Year in Review

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Due to the impact of the COVID-19 pandemic, and the change in presidential administrations in the United States in January 2021, US enforcement of the Foreign Corrupt Practices Act (FCPA) declined in 2021. However, we...more

The Volkov Law Group

The Delaware Court’s Decision Highlights Boeing’s Defective Corporate Culture and Board Governance Failures (Part II of IV)

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When considered in light of the Chancery Court’s decision, DOJ’s essential findings in its Boeing investigation are problematic at best.  The Chancery Court’s decision outlines how Boeing’s culture of safety deteriorated into...more

Society of Corporate Compliance and Ethics...

[Virtual Event] Seattle Regional Compliance and Ethics Conference - November 12th, 8:25 am - 4:30 pm PST

Our Virtual Regional Compliance Conferences provide updates on the latest news in regulatory requirements, compliance enforcement, and strategies to develop effective compliance programs. Watch, listen, and ask questions from...more

Health Care Compliance Association (HCCA)

[Event] Scottsdale Regional Healthcare Compliance Conference - November 5th, Scottsdale, AZ

Our one-day Regional Compliance Conferences provide attendees with a forum to interact with local compliance professionals, share information about your compliance successes and challenges, and create educational...more

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