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OFAC Settles with Individual for $45,179 for Violations of the Global Magnitsky Act

OFAC means what it says — in more ways than one.  In a precedent setting case, OFAC brought its first enforcement action against an individual for violating the Global Magnitsky Sanctions Regulations....more

The Sanctions Year in Review: DOJ takes First Steps to Enforce “The New FCPA” While OFAC’s Enforcement Actions Decline

Enforcement and compliance prognosticators (like myself) continued to push DOJ’s promise to transform sanctions enforcement into the era of “the new FCPA.” While DOJ’s promise to bring about an aggressive corporate...more

DOJ’s Balancing Act — Incentives to Cooperate and Deterrence (Part III of III)

While DOJ did not have an overwhelming FCPA enforcement year, DOJ has devoted significant energy to tweaking its enforcement and compliance policies.  These measures were believed to coincide with a number of significant...more

Episode 352 -- Review of 2024 DOJ and SEC Sanctions Enforcement and Compliance [Audio]

How will your company withstand the heat of aggressive sanctions enforcement? Are you ready for the DOJ’s new priorities and OFAC’s expanding reach in 2025? In this episode of Corruption, Crime, and Compliance, Michael...more

FCPA 2024 Enforcement — Bribery Schemes and Compliance Reminders (Part II of III)

Criminals can be creative — that is a true statement but essentially FCPA criminals have to embrace a variety of well-established techniques to accomplish a straight-forward goal — steal money from the company to funnel...more

The FCPA Year in Review — More of the Same with Some Twists (Part I of III)

With the end of the Biden Administration, it is hard to identify a consistent theme relating to FCPA enforcement.  On the one hand, the Biden Administration talked a big game, elevating the anti-corruption fight as a national...more

C.H. Robinsom Settles with OFAC for $257,690 to Resolve Iran and Cuba Sanctions Violations

C.H. Robinson International Inc. (CHR), a Minnesota-based global transportation and logistics company, has agreed to pay $257,690 to settle civil liability for 82 apparent violations of sanctions against Iran and Cuba...more

Episode 351 -- Deep Dive into the AAR FCPA Settlement [Audio]

How did a high-stakes bribery scheme involving insider deals, Airbus planes, and secret payments bring down a global aviation giant? In this episode, Michael Volkov dives deep into the AAR Corporation FCPA case—a cautionary...more

OFAC Closes Out Year with String of Enforcement Actions — Aiotec Pays OFAC $14.55 Million to Resolve Iran Sanctions Violations

Despite a relatively slow year in OFAC sanctions enforcement, OFAC closed 2024 with a string of settlements in five cases, including its second in 2024 against an individual defendant. While OFAC had a slow year, DOJ...more

AAR’s Bribery Schemes: Bribery in the Aviation Industry (Part II of II)

AAR, a provider of aviation products and services, engaged in two separate bribery schemes. State-owned entities and government agencies permeate the aviation industry. As a result, FCPA risks are embedded in direct...more

DOJ and SEC Close 2024 with FCPA Enforcement Action Against AAR Corp; DOJ and SEC Announces Resolution with Deepak Sharma, CEO of...

The Justice Department and the SEC finished 2024 with a coordinated resolution of criminal and civil FCPA charges against AAR Corporation, an Illinois-based provider of aviation products and services. In addition, DOJ...more

Episode 350 -- Deep Dive into McKinsey FCPA Case [Audio]

What went wrong when McKinsey paid bribes to secure consulting contracts with South Africa's state-owned enterprises? In this episode, Michael Volkov dives into the December 2024 DOJ settlement with McKinsey & Company,...more

DOJ Indicts Indian Billionaire and Seven Other Individuals for Bribery and Fraud Scheme Involving Payments to Indian Government...

In a far-reaching criminal case, in November 2024, the Justice Department unsealed a complex, five-count indictment in the Eastern District of New York charging eight defendants, including Gautam S. Adani, Sagar R. Adani and...more

Lessons Learned from McKinsey’s FCPA Enforcement Action — Local Partners and Third Parties (Part III of III)

Deja Vu all over again — Yogi Berra Yogi Berra said it best — we have seen this scenario before, with similar parties — corrupt foreign officials from Eskom (and Transnet), local partner requirements resulting in engagement...more

McKinsey Company's Bribery Scheme - A Familiar Pattern in South Africa (Part II of III)

The McKinsey FCPA case follows several other significant cases involving South Africa.  ABB and SAP resolved FCPA cases involving bribes in South Africa; on the SEC front, Gartner resolved a bribery case involving South...more

McKinsey Company Pays $122 Million to Resolve FCPA Violations in South Africa (Part I of III)

On December 5, 2024, DOJ announced a settlement with McKinsey and Company for $122 million for bribes paid to South African government officials to secure valuable consulting contracts....more

Antitrust Division Revises Evaluation of Corporate Compliance Programs in Criminal Antitrust Investigations

The Department of Justice Antitrust Division’s is playing catch up to the Criminal Division on compliance leadership.  DOJ’s Criminal Division has issued four separate revisions to its Evaluation of Corporate Compliance...more

BIT Mining FCPA Settlement and Lessons Learned (Part III of III)

Bit Mining, formerly 500.com, was a doomed company from the beginning, When a CEO orchestrates a bribery scheme with the assistance of other senior executives, shareholders and the public have little chance of ensuring a...more

BIT Mining Bribery Scheme — CEO Directed Payments and the Cover-Up (Part II of III)

In reviewing FCPA bribery fact patterns, it is a rare occasion when a company’s CEO is at the epicenter of the criminal conspiracy. In the BIT Mining case, standing atop all of the actors is the CEO Zhengming Pan, Bit...more

BIT Mining CEO Indicted for FCPA Violations — Bit Mining Pays $10 Million to Settle DOJ and SEC FCPA Cases (Part I of III)

Earlier this year, Bit Mining and its CEO fell under the FCPA hammer. Bit Mining, formerly known as 500.com, resolved investigations with the Justice Department and the SEC for its corrupt scheme to bribe Japanese government...more

Antitrust Division AAG Outlines Need for More Aggressive Antitrust Enforcement in the Healthcare Industry

In an interesting political twist, the difference in approaches to antitrust enforcement between Democrat and Republican Administrations has been narrowing. It used to be that the difference in party control of the Antitrust...more

Episode 347 -- LRN's Code of Conduct Survey [Audio]

Have you ever wondered how different cultures and generations engage with a company's code of conduct? Do employees across the globe really follow ethical guidelines in the same way, or are there stark contrasts depending on...more

The Continuing Importance of Conflict of Interest Compliance

We continue to hear about the impact of apparent or real conflicts of interest — whether in government, in business, or in other organizations. It is an issue of significant importance. Within an organization, a perceived...more

Measuring Compliance Program Performance and Effectiveness

You often hear chief compliance officers speak about benchmarking. CCOs often reveal their competitive streaks when they collect information about other companies’ compliance programs. It can easily come off as a little...more

Lessons Learned from the Telefónica FCPA Settlement (Part III of III)

The Justice Department’s record of FCPA enforcement in 2024 has been disappointing.  With all of the hoopla and pronouncements surrounding the global war against corruption, DOJ suggested that enforcement in 2023 and 2024...more

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