In 2017, when President Trump first took office, big changes were expected in FCPA enforcement. Much of this reflected President Trump’s expressed misgivings on the substance of the FCPA. He was not a big fan of the law and...more
1/28/2025
/ Anti-Corruption ,
Compliance ,
Corporate Governance ,
Corporate Misconduct ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Regulatory Reform ,
Securities and Exchange Commission (SEC) ,
Trump Administration ,
U.S. Treasury
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
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
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
What happens when a major defense contractor faces scrutiny for ethics and compliance violations?
In this episode of Corruption, Crime, and Compliance, Michael Volkov dives into the high-stakes world of corporate...more
11/17/2024
/ Arms Export Control Act ,
Bribery ,
Defense Sector ,
Deferred Prosecution Agreements ,
Department of Defense (DOD) ,
Enforcement Actions ,
False Claims Act (FCA) ,
Federal Contractors ,
Foreign Corrupt Practices Act (FCPA) ,
Fraud ,
ITAR ,
Raytheon ,
Securities and Exchange Commission (SEC) ,
Statutory Violations
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 this episode of Corruption,...more
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 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
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
How will the DOJ's new corporate whistleblower pilot program reshape the enforcement of corporate criminal conduct?
In this episode of Corruption, Crime, and Compliance, Michael Volkov explores the Department of Justice's...more
The Securities and Exchange Commission is catching up to DOJ. Not in enforcement but in transparency. After years of criticism, the Justice Department has set the gold standard for transparency and providing guidance on...more
A New York federal district judge handed down a significant decision dismissing much of the SEC's securities fraud enforcement action against SolarWinds arising from its claims relating to SolarWinds' cybersecurity policies,...more
In a significant expansion of internal controls enforcement, the SEC announced a $2.1 million settlement with R.R. Donnelley & Sons Co. ("RRD") for its handling of a 2021 ransomware attack and resulting disclosure failures. ...more
A New Your federal district judge handed down a significant decision dismissing much of the SEC’s securities fraud enforcement action against SolarWinds arising from its claims relating to SolarWinds’ cybersecurity policies,...more
In a significant expansion of internal controls enforcement, the SEC announced a $2.1 million settlement with R.R. Donnelley & Sons Co. (“RRD”) for its handling of a 2021 ransomware attack and resulting disclosure failures. ...more
In a recent decision, Securities and Exchange Commission v. Jarkesy, the Supreme Court voted 6-3 to reject the Securities and Exchange Commission’s use of in-house administrative proceedings to adjudicate securities fraud...more
7/2/2024
/ Administrative Authority ,
Administrative Proceedings ,
Civil Monetary Penalty ,
Constitutional Challenges ,
Enforcement Actions ,
SCOTUS ,
SEC v Jarkesy ,
Securities and Exchange Commission (SEC) ,
Securities Fraud ,
Securities Regulation ,
Seventh Amendment
The increase in internal reporting comes at a critical time when government-sponsored whistleblower programs are maturing and expanding into new agencies. The SEC’s program continues to increase and received a record number...more
After months and months of deliberations and negotiations, the SEC finally issued its final rules for climate disclosures. The Enhancement and Standardization of Climate-Related Disclosures for Investor (“the final rule”)....more
As always, I tend to repeat myself. However, one important point needs to be repeated — DOJ is in the midst of launching an aggressive sanctions and export control program against corporations and individuals. DOJ has...more
1/23/2024
/ Corruption ,
Cryptocurrency ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Export Controls ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Policy ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Securities and Exchange Commission (SEC) ,
White Collar Crimes
A careful reading of the DOJ and SEC settlement documents for the SAP case will puzzle you. I know I am scratching my head trying to make sense of the whole picture here. There are a number of significant indicators of a...more
Life is always filled with surprises. Just when we thought 2023 was a “slow” FCPA enforcement year, DOJ and SEC announced a large enforcement action against SAP for approximately $220 million for FCPA violations in South...more
1/16/2024
/ Bribery ,
Compliance ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Popular ,
Sanction Violations ,
SAP America Inc. ,
Securities and Exchange Commission (SEC) ,
White Collar Crimes
While 2023 was a relatively slow year in FCPA enforcement, the DOJ and SEC settlements announced throughout the year set out a list of important ethics and compliance reminders. While these may seem obvious to everyone, I...more
1/11/2024
/ Anti-Corruption ,
Bribery ,
Compliance ,
Corporate Misconduct ,
Corruption ,
Department of Justice (DOJ) ,
Enforcement Actions ,
FCPA Guidance ,
Foreign Corrupt Practices Act (FCPA) ,
Regulatory Violations ,
Securities and Exchange Commission (SEC) ,
White Collar Crimes
FCPA trends often are relatively easy to describe and often overblown as a marketing technique by the usual cast of paparazzi suspects. (Self-proclaimed prognosticators that often push incorrect themes to promote business,...more
The U.S. Securities and Exchange Commission has a message for publicly-traded companies that suffer a data breach: own up.
On Monday, the SEC sued Texas-based SolarWinds––and its Chief Information Security Officer...more
11/2/2023
/ Corporate Counsel ,
Cyber Attacks ,
Cybersecurity ,
Data Breach ,
Data Protection ,
Enforcement Actions ,
Failure To Disclose ,
Information Technology ,
Investment Fraud ,
Popular ,
Publicly-Traded Companies ,
Regulatory Requirements ,
Securities and Exchange Commission (SEC) ,
SolarWinds