Raytheon Company (Raytheon) — a subsidiary of defense contractor, RTX (formerly known as Raytheon Technologies Corporation) — agreed to pay over $950 million to resolve the Justice Department’s investigations into: (i) a...more
10/29/2024
/ Arms Export Control Act ,
Bribery ,
Compliance ,
Criminal Prosecution ,
Defense Sector ,
Department of Defense (DOD) ,
Department of Justice (DOJ) ,
Enforcement Actions ,
False Claims Act (FCA) ,
Federal Contractors ,
Foreign Corrupt Practices Act (FCPA) ,
Fraud ,
ITAR ,
Raytheon ,
Settlement ,
Statutory Violations
How can companies ensure that their compliance programs are robust enough to handle today’s complex ethical challenges?
In this episode, Michael Volkov dives into the critical components of conducting an internal compliance...more
Teva Pharmaceuticals USA Inc. (Teva USA) and Teva Neuroscience Inc. (“Teva”) agreed to pay $450 million to resolve two matters that allege Teva violated the Anti-Kickback Statute (AKS) and the False Claims Act (FCA). Teva is...more
10/23/2024
/ Anti-Kickback Statute ,
Civil Monetary Penalty ,
Co-payments ,
Drug Pricing ,
Enforcement Actions ,
False Claims Act (FCA) ,
Fraud and Abuse ,
Generic Drugs ,
Health Insurance ,
Healthcare ,
Healthcare Fraud ,
Kickbacks ,
Medicare ,
Pharmaceutical Industry ,
Price-Fixing ,
Teva Pharmaceuticals
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
The Justice Department's Antitrust Division has been aggressively pursuing civil enforcement actions. While criminal enforcement of antitrust laws has been depressed, DOJ has found success in pursuing civil and merger...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
TD Bank’s $3 billion settlement included coordinated regulatory settlements with the Federal Reserve Board (“Federal Reserve”), The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”), and the...more
10/17/2024
/ Anti-Money Laundering ,
Bank Secrecy Act ,
BSA/AML ,
Compliance ,
Criminal Prosecution ,
Enforcement Actions ,
Financial Institutions ,
Financial Services Industry ,
FinCEN ,
FRB ,
OCC ,
Settlement ,
Statutory Violations ,
White Collar Crimes
“By making its services convenient for criminals, TD Bank became one,” Attorney General Merrick B. Garland. TD Bank joins the list of dysfunctional companies — add them to Wells Fargo, Wirecard, Volkswagen, General Motors,...more
10/16/2024
/ BSA/AML ,
Compliance ,
Corporate Culture ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Financial Crimes ,
Financial Institutions ,
Financial Transactions ,
Guilty Pleas ,
Money Laundering
In yet another reminder of the scope of Justice Department enforcement powers, and an important demonstration of the risks of non-compliance, the Justice Department and relevant banking agencies announced a $3 billion...more
10/15/2024
/ Anti-Money Laundering ,
Bank Secrecy Act ,
BSA/AML ,
Compliance ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Financial Institutions ,
Financial Services Industry ,
FinCEN ,
FRB ,
Guilty Pleas ,
OCC ,
Popular ,
Statutory Violations ,
White Collar Crimes
How prepared is your company to handle the evolving risks of artificial intelligence and other emerging technologies in its compliance program?
In this episode of Corruption, Crime and Compliance, Michael Volkov delves into...more
The Justice Department’s Antitrust Division has been aggressively pursuing civil enforcement actions. While criminal enforcement of antitrust laws has been depressed, DOJ has found success in pursuing civil and merger...more
10/8/2024
/ Anti-Competitive ,
Antitrust Violations ,
Banks ,
Competition ,
Debit and Credit Card Transactions ,
Debit Cards ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Exclusionary Clauses ,
Fees ,
Merchants ,
Monopolization ,
Visa Inc
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
The Justice Department announced yet another version of its Evaluation of Corporate Compliance Programs. As everyone knows, the Justice Department’s guidance carries talismanic significance — it is an important document that...more
10/4/2024
/ Anti-Corruption ,
Artificial Intelligence ,
Compliance ,
Compliance Management Systems ,
Corporate Governance ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Enterprise Risks ,
Innovative Technology ,
Machine Learning ,
Risk Management ,
White Collar Crimes
The Commerce Department’s Bureau of Industry and Security (“DOC-BIS”) is adopting procedures to generate voluntary self-disclosures for violations of export controls laws. Companies have to weigh carefully the risks when...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
Foreign companies with U.S. operations are struggling to navigate the landscape of sanctions compliance. OFAC has expressed its concern that foreign companies need to deploy U.S. based expertise and resources to ensure...more
Global companies face significant risks in their supply chains of compliance with OFAC’s economic sanctions regime. OFAC has emphasized the importance of conducting supply chain risk assessments and audits....more
9/26/2024
/ Audits ,
Compliance ,
Cosmetics ,
Due Diligence ,
Enforcement Actions ,
Goods or Services ,
North Korea ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Sanction Violations ,
Suppliers ,
Supply Chain
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
How can companies build trust and drive growth in a region as politically and economically volatile as Latin America? In this episode, Nicolas Garcia - Vice President, Legal, Regional and Compliance Manager for LATAM and...more
The Deere case is an important reminder for companies to devote proper attention to ensuring robust integration planning for acquired companies. DOJ has provided important guidance on acquisition practices and the need to...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
Federal whistleblowers have been exposing health care fraud for years. The False Claims Act (“FCA”) contains robust whistleblower provisions and protections that reward whistleblowers with financial payouts. The process for...more
9/19/2024
/ Anti-Kickback Statute ,
CVS ,
Department of Justice (DOJ) ,
Enforcement Actions ,
False Claims Act (FCA) ,
Fraud and Abuse ,
Health Care Providers ,
Health Insurance ,
Healthcare Fraud ,
Medicare Advantage ,
Whistleblowers
We have seen an explosion in the attention paid to legal, compliance and operational risks companies face in supply chain operations. Depending on the industry, companies have to address a wide-swath of supply chain risks,...more
Diligent conducted numerous board education sessions at which board members spoke about new and significant risks; these included increased stakeholder expectations and the burdensome review of education and documentation...more