The Legal Tightrope: Surviving Parallel Investigations
Navigating Government Contracts: Diana Shaw on Oversight and Whistleblower Protections
The Presumption of Innocence Podcast: Episode 45 - The Grit, Grace and Gift of Second Chances
The Justice Insiders Podcast - The Ever-Expanding Net: Corporate Compliance in an Era of Increasing Trade Sanctions and Restrictions
False Claims Act Insights - Are All Healthcare “Kickbacks” Subject to FCA Liability?
Episode 333 -- The Boeing Proposed Plea Agreement
DOJ’s New Self-Disclosure Policy and Corporate Whistleblower Awards Pilot Program
False Claims Act Insights - Assessing the Fallout from a Thermonuclear FCA Verdict
FCPA Survival Guide - Step 8 - Investing in Compliance
Exploring the AI and Crypto Intersection
The Justice Insiders Podcast: Jarkesy’s Implications for the Administrative State
The Presumption of Innocence Podcast: Episode 41 - The Dynamics of Decision-Making: Psychology and the Criminal Justice System
INTERPOL and Child Kidnapping Cases. What are INTERPOL’s Abilities and Limitations?
False Claims Act Insights - Eureka! Government Investigators Seek Out Research Misconduct
The Justice Insiders Podcast - AI-Washing: Everything Old Is New Again
The CFPB and State AGs Act Jointly Against Online Educational Company
Will the U.S. Have a GDPR? With Rachael Ormiston of Osano
Episode 328 -- Sanctions Enforcement Risks and Redlines
FCPA Survival Guide: Step 3 - Extensive Remediation
Episode 324 -- Third-Party Risks and Sanctions Compliance
The end of the road for Roger Ng, the Goldman Sachs Investment Banker, who played a critical role in the Goldman Sachs 1 MDB Malaysia scandal, was not a pretty one. District Judge Margo Brodie gave Ng a severe sentence of...more
In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important SEC enforcement developments from the past month, with links to primary resources....more
Each FCPA case provides valuable lessons in the mechanics of bribery schemes and the common techniques used by violators to secure funds and make illegal payments to foreign government officials. Criminal violators often act...more
Talk about a reminder of the past, Asante Berko, a former Executive Director in Goldman Sachs, recently was arrested in London on criminal FCPA charges arising from his involvement in a bribery scheme in Ghana....more
On April 1, 2022, the Board of Governors of the Federal Reserve System issued an Order of Prohibition against Joseph A. Jiampietro, a former managing director of Goldman Sachs’ Financial Institution Group (“GSFIG”),...more
There is much to be learned from reviewing the wreckage of a major Justice Department enforcement action. It is helpful to identify these themes, analyze the conduct and reasons for the violation, and identify helpful...more
Walgreens has named Starbucks exec Roz Brewer as its new CEO. The move sets up Brewer to be “the only Black female leading a Fortune 500 company”...more
Well, it is that time again. I get to put on my Carnac the Magnificent Hat and offer my FCPA predictions for 2021. I should get a pass on my 2020 FCPA Predictions posting because no one could have anticipated the COVID-19...more
DOJ and the SEC each had a great year in FCPA enforcement. But it is important to acknowledge that the blockbuster case, Goldman Sachs, was the driver of this successful year. ...more
The Justice Department and the Securities and Exchange Commission had another record year of enforcement. In fact, the last four years of FCPA enforcement included two years of record enforcement – 2019 and 2020. After...more
The FAA has once again given Boeing the green light to send its troubled 737 Max models into the sky, “20 months after it was grounded following two fatal crashes blamed on faulty software and a host of company and government...more
We conclude our exploration of The Goldman Sachs Group, Inc. (Goldman Sachs) Foreign Corrupt Practices Act (FCPA) settlements and related enforcement action, literally across the globe, from the state of New York to...more
Goldman Sachs now sits atop all charts with the largest US FCPA bribery penalty, totaling approximately $2.9 billion. The second largest is Ericsson’s 2019 FCPA settlement for $1 billion....more
Last week, the Securities and Exchange Commission (“SEC”) filed charges against Asante Berko, a former Goldman Sachs executive with bribery of foreign government officials in Ghana. Goldman Sachs discovered and stopped the...more
The OCC announced yesterday that it’s bringing enforcement actions against five former Wells Fargo bank executives as part of their alleged roles in the bank’s sales practices scandal. The agency further revealed that it’s...more
It is time to break out the crystal ball for FCPA 2020 Predictions. In preparing for this, I always rely on my past admiration of Carnac the Magnificent....more
Goldman Sachs is reportedly in negotiations with federal prosecutors to resolve claims about its role in the Malaysian 1MDB scandal for upwards of $2 billion. A settlement—which “could include a guilty plea from Goldman’s...more
I thought Frosty was a good analogy to consider the disgraced Goldman Sachs Group Inc.’s former partner Tim Leissner, as he is certainly back again. Yesterday, I begin a two-part blog post series on Leissner’s settlement with...more
Here’s about as 2019 as we can get in the financial world (with a healthy dose of 1950s-era gender discrimination for good measure): a series of tweets from tech entrepreneur David Heinemeier Hansson alleging gender...more
As reported by Byron Tau and Aruna Viswanatha in the Wall Street Journal (WSJ), “Jho Low, the businessman-turned-fugitive accused of masterminding a multibillion-dollar fraud involving Malaysia’s sovereign-wealth fund, agreed...more
In recent weeks, the Office of Federal Contract Compliance Programs (“OFCCP”) has entered into four major settlements that are notable both for their size, and for highlighting current trends. Each case involved allegations...more
As universally expected, the Fed’s Open Market Committee delivered its third interest rate cut of 2019 yesterday, though it did so while signaling that it’s likely to pause before taking action again and “is now shifting into...more
A last-minute deal between defendants McKesson, Cardinal Health, AmerisourceBergen, and Teva and plaintiffs’ attorneys means that multidistrict opioid epidemic litigation set to kick off in Ohio federal court today will not...more
The OFCCP opened the month of October by announcing three multimillion dollar settlements with major government contractors. The agency entered into early resolution conciliation agreements with Goldman Sachs & Co. LLC and...more
Google will pay a “record $170 million fine and make changes to protect children’s privacy on YouTube” as part of a deal it reached this week with the FTC and NY AG’s office, both of whom had accused YouTube of “violating the...more