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Episode 335 -- The New DOJ Whistleblower Program [Audio]

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

DOJ Awards Declination to Proterial Cable America for Fraud — Proterial Pays $15.1 Million in Disgorgement

DOJ is pushing hard for voluntary disclosures and urging companies to take advantage  of its Voluntary Disclosure Program.  The carrot is significant — a declination in exchange for cooperation, remediation and disgorgement....more

DOJ Issues New FCPA Declination: Boston Consulting Group Pays $14.4 Million

The Justice Department is encouraging companies to voluntarily disclose criminal violations — “Come in and confess” and DOJ offers promises of a declination.  But even a declination comes with a requirement — the company has...more

The Compliance “Curse” — Learning to Compromise Principles

Compliance lessons are life lessons.  Compliance professionals are, by their nature, optimistic people. They see challenges as new opportunities to strive closer to an ideal.  Compliance professionals live in the shadow of...more

Tracking FCPA Individual Enforcement

While FCPA enforcement against companies has been relatively quiet this year, despite a strong beginning to the year — the SAP case for $220 million; and the Gunvor case for $661 million — DOJ has been pushing a number of...more

DOJ’s New Whistleblower Program: Filling in the Gaps and Encouraging Tips (Part II of II)

DOJ is joining the whistleblower reward sweepstakes in a big way.  While the SEC has been grabbing headlines for its whistleblower reward program since 2010, DOJ now wants a piece of the action.  DOJ cited gaps that exist...more

DOJ Implements New Corporate Whistleblower Plan to Accelerate Corporate Criminal Enforcement (Part I of II)

DOJ is feeling the heat.  Corporate criminal enforcement numbers are down. in fairness, DOJ has been pushing individual criminal enforcement as an effective deterrent to corporate misconduct.  Criminal prosecutions, when done...more

Episode 333 -- The Boeing Proposed Plea Agreement [Audio]

The Boeing 737 MAX case took another dramatic turn.  On July 24, 2024, the Department of Justice filed with the United States District Court for the Northern District of Texas a proposed plea agreement with Boeing.  The plea...more

Boeing’s Failure to Integrate Compliance Anti-Fraud Controls with Quality and Safety Functions (Part III of III)

Boeing’s Plea Agreement includes two Separate Factual Statements — the January 7, 2021 DPA, which is discussed in a prior blog post, and a factual outline of Boeing’s breach of the original DPA, resulting in the current Plea...more

Deep Dive into Proposed Boeing Plea Agreement (Part II of III)

DOJ and Boeing have entered into a proposed plea agreement that will require judicial scrutiny and determinations of the public interest and the victims’ rights under the Crime Victims’ Rights Act, 18 U.S.C. § 3771 [“CVRA”]. ...more

Episode 330 – Halyna Senyk on Anti-Corruption Progress in Ukraine [Audio]

Listen to this conversation between Michael Volkov and Halyna Senyk in which they focus on Ukraine's anti-corruption efforts amidst the backdrop of its ongoing war with Russia. Halyna Senyk, an expert from the CEELI...more

Is Your Sanctions Compliance Program Compliant? — A Quick Five-Question Quiz

Checklists can be handy — by simplifying and focusing on specific issues, a checklist can organize thinking and prioritize tasks. Here are five (5) questions that are fairly simple but revealing as to whether a company’s...more

LRN’s Call to Action: 5 Steps Every Company Should Take to Promote an Ethical Culture (Part II of II)

LRN’s  research consistently paints a picture that every board member, senior executive and middle manager should view — corporate culture is an organization’s most valuable intangible asset and is a significant determinant...more

Episode 324 -- Third-Party Risks and Sanctions Compliance [Audio]

With the beginning of the “New FCPA” era coined by DOJ’s Deputy Attorney General Lisa Monaco, we now need to focus on third-party risk and sanctions enforcement. The law, the practice, and the risks are important and not just...more

LRN Report Highlights (Again) the Importance of Ethical Culture (Part I of II)

In its latest report, The 2024 Benchmark of Ethical Culture Report, LRN has focused on the critical issue of corporate culture.  LRN is a pacesetter and the leader in reliable studies on complex ethics and compliance issues....more

The Magnificent Seven: Important Ways to Mitigate Your Third-Party Sanctions Risks (Part IV of IV)

It may seem like a Herculean task — but it can be done.  I regularly opine that mitigating sanctions risks for your third-party population is an easier task than doing so for your anti-corruption risks.  One big reason —...more

The Same Old Song with a Different Meaning — Third-Party Risks and Sanctions Compliance (Part I of IV)

Sorry to start a four-part series with a reference to music from our long-ago past.  The Four Tops sang the “Same Old Song, with a Different Meaning” (released in 1965). So, how does that relate to third-party risks?  Well,...more

The Power and Reward of Cooperation: Binance Founder CZ Sentenced to 4 Months Imprisonment

Defendants often face a tough choice — challenge the government’s evidence and if convicted, face significant jail time.  On the flip side, defendants who plead guilty and cooperate can earn significant sentencing reductions,...more

NAVEX 2024 Whistleblower Report Highlights Important Trend — More Reports are Being Made and More Are Being Substantiated

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

DOJ, Commerce and Treasury Issue JCN on Foreign Person Liability for Sanctions and Export Controls Violations

As DOJ, OFAC and BIS ramp up sanctions and export controls enforcement, they have continued to provide important compliance guidance.  You have to give the enforcement agencies credit — on the one hand, they regularly warn of...more

Lessons-Learned from the Trafigura FCPA Settlement (Part III of III)

The Justice Department is rightly trumpeting its successful sweep of the commodities trading industry.  DOJ’s success is reflected in its six separate corporate resolutions and 20 individual convictions, resulting in over...more

Trafigura’s Bribery Scheme: Clandestine Meetings, 3rd Parties and Shell Companies (Part II of III)

Trafigura’s bribery scheme resembles the same schemes implemented by its significant competitors — Vitol, Glencore, Gunvor.  At the core of the conduct, Petrobras and Brazilian government officials collected bribes in...more

Trafigura Joins the FCPA Enforcement Club: Pleads Guilty and Pays Over $126 Million for Bribery Violations in Brazil (Part I of...

On the heels of the Gunvor FCPA settlement for $661 million, DOJ announced its settlement with Trafigura, the latest commodities trading company to fall under DOJ’s FCPA Sweep against the industry.  Trafigura joined the list...more

Carrots and Sticks: DOJ’s Push to Incentivize Voluntary Disclosure of Corporate Misconduct (Part II of II)

DOJ has been on a public relations campaign to push a simple message for corporations: if companies learn of misconduct, companies should disclose such misconduct to earn valuable benefits.  The quintessential question...more

DOJ Enters Whistleblower Sweepstakes — Plans to Implement Bounty Program (Part I of II)

The Securities and Exchange Commission has gained well-publicized traction through its formal whistleblower bounty program.  Only a small portion of these whistleblower reports involve FCPA, anti-bribery allegations. ...more

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