Daily Compliance News: May 19, 2025, The Definition of Corruption Edition
10 For 10: Top Compliance Stories For the Week Ending May 10, 2025
Compliance into the Weeds: USRA Declination Case Study - Self-Disclosure Best Practices
Daily Compliance News: April 8, 2025, The End of Monitors Edition
10 For 10: Top Compliance Stories For The Week Ending April 5, 2025
2 Gurus Talk Compliance: Episode 48 – The March Madness Edition
10 For 10: Top Compliance Stories For The Week Ending, March 22, 2025
Regulatory Ramblings: Episode 65 – The Trump Administration’s Decision to Halt FCPA Enforcement – The Implications for Asia and the World with Tom Fox, Malcolm Nance, and Philip Rohlik
Daily Compliance News: March 19, 2025, The Why CISOs Quit Edition
10 For 10: Top Compliance Stories For the Week Ending March 15, 2025
Episode 356 -- Trump Administration Hits Pause on FCPA Enforcement
Episode 351 -- Deep Dive into the AAR FCPA Settlement
Episode 350 -- Deep Dive into McKinsey FCPA Case
Corruption, Crime & Compliance: BIT Mining Resolves FCPA Case for $10 Million and CEO Pan Indicted
Episode 349 -- Review of the BIT Mining FCPA Settlement
Episode 345 -- Raytheon Pays $950 Million to Resolve Fraud, FCPA, ITAR and False Claims Act Violations
Episode 344 -- SEC Settles FCPA Case with Moog for $1.7 Million
Episode 339: Four Sanctions Cases Everyone Should Know
Episode 338 -- Deep Dive into the Deere SEC FCPA Case
Wicked Coin: The "Fat Leonard" Scandal
Power and corruption … two sides of a wicked coin. In this podcast, hosts Tatiana Sainati and Diana Shaw tell the stories of the world’s largest, most salacious corruption scandals and explore the myriad ways in which...more
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
Albemarle Corporation (Albemarle), recently agreed to pay more than $218 million to resolve investigations by the U.S. Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) into violations of the...more
The Securities and Exchange Commission continues to rack up FCPA enforcement actions. In its latest settlement, Clear Channel Outdoor Holdings agreed to pay $26.1 million for bribery violations committed by its former...more
The Department of Justice has been relatively quiet this year in bringing corporate FCPA enforcement actions and settlements. Aside from the Ericsson breach of its Deferred Prosecution Agreement, the Corficocolombiana...more
The Justice Department continues to push an aggressive agenda against businesses. It is committed to demonstrating its resolve to prosecute companies and individuals from the business community. Whether it is antitrust,...more
Oracle’s SEC settlement for $23 million underscores the power of the FCPA provisions mandating effective internal controls and accurate books and records. As everyone knows, these provisions can be applied to a wide-range of...more
GOL’s bribery schemes present some interesting lessons. Interestingly, at the center of the bribery scheme was a member of GOL’s board of directors. The bribery scheme was motivated by potential legislation that would...more
The Second Circuit Court of Appeals affirmed the district judge’s post-conviction dismissal of FCPA counts against Lawrence Hoskins, a former Alston executive, for his involvement in bribery scheme to secure a $118 million...more
The SEC announced its first FCPA enforcement action in 2022. South Korean telecommunications company, KT Corporation, agreed to pay $6.3 million to settle FCPA violations. As part of the settlement, KT Corp. agreed to pay...more
After a long hiatus, the SEC announced a settlement with WPP plc, the world’s largest advertising group, for FCPA violations in India, China, Brazil and Peru for $19.2 million. The SEC’s resolution charges WPP with...more
Raymond Kohut, a 68-year old Canadian citizen, a former employee of Swiss commodities trader, Gunvor Group, Ltd., pleaded guilty to paying $22 million in bribes to Ecuadoran government officials at state-owned oil company,...more
DOJ and the SEC each had a great year in FCPA enforcement. But it is important to acknowledge that the blockbuster case, Goldman Sachs, was the driver of this successful year. ...more
In a landmark action on December 3, 2020, the Commodity Futures Trading Commission (“CFTC”) announced resolution of its first enforcement action involving foreign corruption by issuing an order and settling charges against...more
Goldman Sachs now sits atop all charts with the largest US FCPA bribery penalty, totaling approximately $2.9 billion. The second largest is Ericsson’s 2019 FCPA settlement for $1 billion....more
We all know it when we see it – a recurring fact pattern in which a company enlists a corrupt third party intermediary for one purpose (and one purpose only) – to pay a bribe. Let me give you a few examples....more
The Justice Department continues to pursue criminal cases against Venezuelan officials at Petróleos de Venezuela S.A. (PDVSA) in an attempt to strangle President Nicolas Maduro. DOJ has been pursuing a three-pronged strategy...more
World Acceptance Corporation (“WAC”), a US-based consumer loan company, agreed to pay the SEC $21.7 million for FCPA violations in Mexico. WAC’s cited violations covered the full gamut of FCPA violations, including bribery...more
Over the past several blog posts, I have been exploring the Airbus SE (Airbus) international anti-corruption settlement in some depth. One of the questions I have had and hopefully raised for readers is not why the overall...more
Last week, Airbus SE (Airbus) settled a long-standing corruption scandal by agreeing to enforcement actions in three countries; France, the United Kingdom and the US. The matter involved a massive, worldwide, long running...more
When reviewing a major enforcement case, I always ask two basic questions: What was the role of Board and senior management in the failure, and how did they fail to exercise proper oversight and ensure compliance?...more
The Justice Department has brought only a few enforcement actions that focus on FCPA and export control violations. Last year, Quad Graphics earned a declination for FCPA and OFAC violations. In 2013, Weatherford settled...more
Almost every FCPA enforcement action contains important lessons learned in unraveling a bribery scheme. Airbus has three broad divisions: (1) Commercial Division; (2) Defense & Space Division; and (3) Helicopters...more