How do you manage risk when the vulnerabilities are outside your organization aren’t in your hands?
In this episode of Corruption, Crime, and Compliance, we delve into the world of third-party risk management with our...more
Are You Ready for the Next Wave of Corporate Risk?
Corporate risks are shifting, and every board, C-suite, and compliance team must take a fresh look at their risk landscape.
While some risks like cybersecurity, data...more
What happens when an entire era of anti-corruption enforcement is put on pause?
Is this a strategic move to bolster American businesses or a dangerous rollback of corporate accountability?
In an unprecedented move, the...more
As we continue through the maze of Executive Orders and new Guidance, which is expected in 180 days, the questions surrounding FCPA enforcement are swirling. In some respects, we have had a preview. It is hard to know what...more
2/12/2025
/ Anti-Corruption ,
Corruption ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
International Emergency Economic Powers Act (IEEPA) ,
National Security ,
OECD ,
Regulatory Agenda ,
Regulatory Freeze ,
RICO ,
White Collar Crimes
The 1990s saw the explosion of the internet, transforming the global economy and social development in ways we could have never imagined. But will AI truly have the same impact?
While its potential is undeniable, the road...more
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
1/16/2025
/ Anti-Corruption ,
Bribery ,
Compliance ,
Corporate Governance ,
Corruption ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Third-Party Risk ,
White Collar Crimes
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
1/8/2025
/ Anti-Corruption ,
Aviation Industry ,
Bribery ,
Compliance ,
Corporate Fraud ,
Corruption ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Securities and Exchange Commission (SEC) ,
White Collar Crimes
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
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
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
12/20/2024
/ Bribery ,
Compliance ,
Corruption ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
False Statements ,
Fraud ,
India ,
Indictments ,
Misleading Statements ,
Public Contracts ,
Solar Energy ,
White Collar Crimes
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
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
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
12/18/2024
/ Bribery ,
Compliance ,
Corruption ,
Criminal Investigations ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Guilty Pleas ,
Settlement ,
White Collar Crimes
What happens when a Chief Executive Officer becomes the architect of a global bribery scheme?
In this episode of Corruption, Crime, and Compliance, Michael Volkov delivers an in-depth analysis of the BIT Mining FCPA case —...more
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
We should all admit something (among many things) — reading through factual statements of bribery offenses, the facts all start to meld together. Criminals are not as ingenuous or creative as they think, and the schemes they...more
Telefónica Venezolana C.A. (“Telefónica Venezolana”), the Venezuela-based subsidiary of Telefónica S.A. (Telefónica), the Spanish telecommunications company entered into a deferred prosecution agreement (“DPA”) and agreed to...more
How does a respected financial institution turn into a criminal operation? In this episode of Corruption, Crime, and Compliance, host Michael Volkov dives into the record-breaking $3 billion settlement between TD Bank and the...more
Raytheon’s criminal conduct cut across a variety of topics — it is difficult to imagine but Raytheon’s misconduct occurred in separate parts of the company, involving violations of different laws. Like most cases, I always...more
10/31/2024
/ Compliance ,
Corporate Culture ,
Corporate Misconduct ,
Corruption ,
Criminal Investigations ,
Defense Sector ,
Department of Defense (DOD) ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Federal Acquisition Regulations (FAR) ,
Federal Contractors ,
Fraud ,
Leadership ,
Pricing ,
Raytheon
The SEC notched another FCPA settlement, continuing its steady pursuit and resolution of FCPA cases. In the meantime, the Justice Department has been silent in the FCPA enforcement arena. In its latest settlement, Moog,...more
TD Banks’ complete compliance disaster was reflected in every aspect of TD Bank’s business and compliance operations. It is not surprising that TD Bank’s deficient BSA and AML compliance program was known by its Board of...more
10/18/2024
/ Anti-Money Laundering ,
BSA/AML ,
Compliance ,
Corruption ,
Criminal Prosecution ,
Enforcement Actions ,
Financial Crimes ,
Financial Institutions ,
FinCEN ,
Money Laundering ,
OCC ,
White Collar Crimes
How prepared is your organization to handle the evolving landscape of sanctions compliance?
In this episode of Corruption, Crime and Compliance, Michael Volkov dives into critical sanctions compliance cases and their...more
We are all familiar with — over and over — third-party risks and FCPA risks. It is drilled in our collective heads — third-party risks and bribery. Legal and compliance professionals have to learn and understand the ins...more
The Justice Department has repeated on several occasions that it intends to aggressively prosecute corporations for sanctions and export controls violations. The “New FCPA” is how the Justice Department characterizes its...more
The SEC’s recent settlement with Deere & Company for $9.9 million for FCPA violations is another textbook example of bribery schemes, which revealed the absence of a culture of compliance, and the circumvention of basic...more