On September 27, 2021, the Office of Foreign Assets Control (“OFAC”) of the U.S. Department of Treasury announced a $1,423,766 settlement with Houston-based supplier, Cameron International Corporation (“Cameron”) to resolve...more
11/9/2021
/ Compliance ,
Corporate Counsel ,
Economic Sanctions ,
Enforcement Actions ,
Executive Orders ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Sanction Violations ,
SDN List ,
Settlement Negotiations ,
Ukraine
On April 29, 2021, the Office of Foreign Assets Control (“OFAC”) of the U.S. Department of Treasury, and the Bureau of Industry and Security (“BIS”) of the U.S. Department of Commerce announced settlements with German...more
5/26/2021
/ Attorney General ,
Bureau of Industry and Security (BIS) ,
Civil Monetary Penalty ,
Compliance ,
Corporate Counsel ,
Data Blocking ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Geo-Blocking ,
Geolocation ,
Germany ,
Iran ,
Iran Sanctions ,
ITAR ,
ITSR ,
Office of Foreign Assets Control (OFAC) ,
SAP SE ,
Settlement ,
Technology Sector ,
U.S. Treasury
The Department of Justice tweaked its FCPA Corporate Enforcement Policy to further incentivize corporations to make voluntary disclosures. These small changes essentially acknowledge that companies in a very early stage of an...more
In recent weeks, the United States Department of Justice (“DOJ”) published guidance in the Justice Manual at Section 4-4.112 on how it will award cooperation credit to entities and individuals that are being investigated for...more
7/29/2019
/ Chief Compliance Officers ,
Compliance ,
Cooperation ,
Corporate Counsel ,
Corporate Liability ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
False Claims Act (FCA) ,
Federal Contractors ,
Government Investigations ,
New Guidance ,
Remedial Actions ,
Subsequent Remedial Measures ,
Voluntary Disclosure Agreement
The SEC’s most recent whistleblower awards highlight the importance of internal reporting to a company’s compliance program and especially how a company investigates and responds to such reports. On May 24, 2019, the SEC...more
When DOJ announced its FCPA Corporate Enforcement Policy in 2017 (later expanded to all corporate criminal defendants), defense lawyers expressed concern about a provision buried within what it meant to provide “timely and...more
Following a recent federal court ruling, parties contemplating an advice of counsel defense must consider carefully the scope of the accompanying attorney-client privilege waiver. In United States ex rel. Lutz v. Berkeley...more
For the next year, the Justice Department may be offering up to a 50% discount on fines imposed in FCPA cases. Yesterday, the U.S. Department of Justice’s (“DOJ”) Criminal Division announced the launch of a one-year pilot...more
4/7/2016
/ Compliance ,
Cooperation ,
Corporate Counsel ,
Corporate Misconduct ,
Corruption ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Federal Pilot Programs ,
Federal Sentencing Guidelines ,
Foreign Corrupt Practices Act (FCPA) ,
Individual Accountability ,
Remediation ,
Self-Disclosure Requirements ,
Voluntary Disclosure ,
White Collar Crimes