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White Collar Crimes Civil Monetary Penalty

The Volkov Law Group

Gunvor’s Blockbuster FCPA Settlement: Lessons Learned and Trends (Part III of III)

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The Department of Justice’s blockbuster FCPA settlement with Gunvor restores the credibility of DOJ’s pronouncements of DOJ’s commitment to aggressive FCPA enforcement.  While I have questioned DOJ’s commitment to its...more

Cadwalader, Wickersham & Taft LLP

Insider Trading in Physical Commodities

On December 14, 2023, the Commodity Futures Trading Commission (“CFTC”) and Department of Justice (“DOJ”) Fraud Section announced the settlement of insider trading fraud charges and Foreign Corrupt Practices Act (“FCPA”)...more

Thomas Fox - Compliance Evangelist

3M in China-Where Secret Travel = FCPA Violations

You know that when the Securities Exchange Commission (SEC) uses the word ‘secretly’ when discussing a corporate program, it is a seriously not good look. That is certainly the case in the recently announced Foreign Corrupt...more

The Volkov Law Group

3M Corp Pays SEC $6.5 Million to Resolve FCPA Charges

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The SEC is having a good year in prosecuting FCPA cases.  The SEC’s recent settlement with 3M Corp. for $6.5 million is its seventh corporate resolution for the year.  DOJ, which has been relatively quiet so far this year,...more

The Volkov Law Group

Corficocolombiana and Grupo Aval Pay $80 Million to Settle DOJ and SEC FCPA Violations in Colombia (Part I of II)

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The Department of Justice has been relatively quiet this year in bringing corporate FCPA enforcement actions and settlements.  Aside from the Ericsson breach of its Deferred Prosecution Agreement, the Corficocolombiana...more

Latham & Watkins LLP

France’s New Guidelines on Deferred Prosecution Agreement Offer Welcome Clarity

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The guidelines provide useful insights into the mechanism of settlement agreements in criminal cases, and supersede previous guidelines published on June 26, 2019. Article 22 of Law No. 2016-1691 of December 9, 2016...more

Cadwalader, Wickersham & Taft LLP

Sanctions Watch: UK Authority Outlines Powers to Impose Strict Liability Civil Penalties

Summary - From 15 June 2022, the Office of Financial Sanctions Implementation (“OFSI”) has the power to issue monetary penalties for breaches of financial sanctions on a strict liability basis. The newly-published...more

The Volkov Law Group

Tenaris Pays SEC $78 Million to Resolve FCPA Violations

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The SEC announced another FCPA settlement in 2022.  FCPA enforcement, in general, is picking up.  Tenaris, a global supplier of steel pipes and related services for the energy industry, agreed to pay the SEC $78 million to...more

Perkins Coie

DOJ’s False Claims Act Recoveries Jump to $5.6 Billion in FY 2021

Perkins Coie on

The U.S. Department of Justice (DOJ) recovered more than $5.6 billion in civil False Claims Act (FCA) judgments and settlements in fiscal year (FY) 2021, the second largest ever annual total in FCA recoveries and the largest...more

Steptoe & Johnson PLLC

Strike Force Takes Renewed Aim at Health Care Fraud and Abuse and Encourages Whistleblowers

Steptoe & Johnson PLLC on

The United States Attorney’s Office for the Northern District of West Virginia announced a renewed emphasis on health care fraud prosecutions in West Virginia as of January 19, 2022. It formed the Mountaineer Health Care...more

Foley & Lardner LLP

Five Developments Identified in Criminal and Civil Enforcement of PPP Loans

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Recently, the Beverly Hills Bar Association in California sponsored a panel presentation on “PPP Enforcement Trends,” whose panelists included a high-level prosecutor from the United States Attorney’s Office and other leading...more

BakerHostetler

Important Lessons from the DOJ's First Civil Action for CARES Act Loan Fraud

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On January 12, 2021, the Department of Justice (the “DOJ”) settled its first civil action for alleged fraud against the Paycheck Protection Program (the “PPP”) – the primary lending program under the Coronavirus Aid, Relief,...more

The Volkov Law Group

Cardinal Health Pays SEC $8.8 Million for FCPA Violations

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Cardinal Health (“Cardinal”) agreed to pay the SEC $8.8 million for FCPA violations in China relating to its internal controls and books and records. Cardinal acknowledged facts relating to internal controls deficiencies and...more

Thomas Fox - Compliance Evangelist

Cardinal Health FCPA Enforcement Action: High Risk Business Relationships

Cardinal Health Inc. (Cardinal) settled its Foreign Corrupt Practices Act (FCPA) matter with the Securities and Exchange Commission (SEC) last week. According to the SEC Press Release, Anita B. Bandy, Associate Director in...more

Hogan Lovells

CFTC charges Colorado man with fraud in digital asset-linked Ponzi scheme

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The U.S. Commodity Futures Trading Commission (CFTC) has charged a man from Colorado with fraud and failing to register with it in respect of a scheme that involved Ponzi-type payments....more

Hogan Lovells

U.S. SEC and Longfin CEO settle fraud action

Hogan Lovells on

The SEC has settled its fraud action against Longfin CEO Venkata Meenavalli, who has agreed to pay $400,000 in disgorgement and penalties. The SEC's complaint alleged that Longfin and Meenavalli obtained qualification for...more

Thomas Fox - Compliance Evangelist

Top SEC Enforcement Actions from 2019

Yesterday, I considered five Department of Justice (DOJ) Foreign Corrupt Practices Act (FCPA) enforcement actions. Today, I want to look at key FCPA enforcement actions by the Securities and Exchange Commission (SEC)....more

White & Case LLP

President Trump's trade wars and the expansion of customs violations into the white-collar space

White & Case LLP on

The US' ongoing trade wars—with various trading partners and particularly with China—are everywhere in the news. Putting politics and policy aside, the "trade wars" reflect a basic disagreement over the rules that should...more

Foley Hoag LLP - White Collar Law &...

DOJ Issues Guidance on Corporate Poverty Claims

On Tuesday, October 8, 2019, the Department of Justice provided guidance on how its prosecutors should evaluate claims of corporate poverty. This comes on the heels of Deputy Assistant Attorney General Matthew Miner’s...more

Manatt, Phelps & Phillips, LLP

[Webinar] Fraud and Abuse Trends: Critical Issues for Health Plans - October 17th, 1:00 pm ET

In FY 2018, the federal government won or negotiated more than $2.3 billion in healthcare fraud judgments and settlements. During that same period, investigations conducted by the Department of Health and Human Services’...more

The Volkov Law Group

Quad/Graphics Settles SEC FCPA Case for Nearly $10 Million

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Quad/Graphics, a Wisconsin print and digital marketing company agreed to pay the SEC almost $10 million to settle FCPA charges for foreign bribery violations in Peru and China. ...more

Thomas Fox - Compliance Evangelist

Year End (FCPA) Closeouts: Quad/Graphics, Barclays and Westport Fuel Systems

The US government fiscal year ends today. Just as in the business world, where many companies try and clear out any unexecuted deals or open contracts, we saw the Securities and Exchange Commission (SEC) clear out three...more

The Volkov Law Group

Applying OFAC’s Sanctions Enforcement Guidelines to Determine A Civil Monetary Penalty (Part II of II)

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In yesterday’s posting, I examined the General Factors identified by OFAC to determine whether to initiate a civil penalty proceeding and the amount of any civil monetary penalty.   After analyzing these factors, OFAC...more

The Volkov Law Group

OFAC Joins the Compliance Club – Issues Framework for Sanctions Compliance Programs (Part I of IV)

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On the heels of the Justice Department’s announcement of its new compliance guidance, on May 2, 2019, the Treasury Department’s Office of Foreign Asset Control (“OFAC”) issued its promised guidance for sanctions compliance...more

BCLP

Anti-Corruption Enforcement Webinar: 2018 in Review

BCLP on

Anti-Corruption enforcement remained a top priority in France, the UK, and the US in 2018. Join our firm's Global Anti-Corruption Team as they explain and analyze these three countries' anti-corruption enforcement efforts and...more

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