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Compliance Accounting Fraud

Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory violations. ... more +
Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory violations.  In response to many corporate scandals evidencing rampant unethical business practices, many nations, including the United States, began passing strict regulatory frameworks aimed at curbing these abuses. Notable pieces of legislation in this area include the U.S. Foreign Corrupt Practices Act (FCPA), Sarbanes-Oxley (SOX), and the U.K. Bribery Act, to name a few. The foregoing statutes and the severe penalties often associated with them form the basis of many modern institutional compliance programs. less -
The Volkov Law Group

VMware pays SEC $8 Million for Misleading Financial Reporting

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The Securities and Exchange Commission’s bread-and-butter enforcement actions focus on accounting fraud.  The SEC has a long history in uncovering fraudulent financial reporting schemes.  In the early 2000s, Wall Street was...more

Thomas Fox - Compliance Evangelist

The Fourth Estate and Wirecard

It is one thing to wake up and find yourself as the lead story on a Sunday morning when the New York Times (NYT) runs a corruption story about your organization above the fold. It is quite another when the world’s top...more

Burr & Forman

Walmart FCPA Settlement Shines Light On Corporate Compliance Programs

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June 20, 2019 – Walmart (NYSE: WMT) and its subsidiary, WMT Brasilia, agreed to a combined criminal penalty and disgorgement of $282M, together with WMT’s criminal guilty plea and undertakings in an NPA, to reach a global...more

Thomas Fox - Compliance Evangelist

Walmart FCPA Enforcement Action: Part 1 – Introduction

The big one finally is resolved. The long-awaited Walmart Inc. (Walmart) Foreign Corrupt Practices Act (FCPA) enforcement action was announced yesterday. This massive case came in with multiple documents, a long list of...more

Thomas Fox - Compliance Evangelist

Stryker FCPA Enforcement Action: Compliance Lessons For Distributors and Dealers – Part II

Over this two-part blog post series, I have been considering the Stryker Corporation 2018 Foreign Corrupt Practices Act (FCPA) enforcement action brought by the Securities and Exchange Commission (SEC)....more

The Volkov Law Group

Stryker Suffers “Strike Two” and Settles SEC FCPA Case

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Stryker Corporation has suffered a second FCPA enforcement action, and will now bear the stigma of FCPA “recidivist.” In reaching a settlement with the SEC and agreeing to pay a $7.8 million civil penalty, Stryker will now...more

The Volkov Law Group

Dun and Bradstreet Pays $9 Million for FCPA Violations in China

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After a lengthy investigation, Dun and Bradstreet (D&B) settled an FCPA enforcement action with the Securities and Exchange Commission for $9 million. ...more

The Volkov Law Group

Compliance Lessons Learned from Panasonic Avionics $280 Million FCPA Enforcement Action (Part II of II)

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The Panasonic Avionics (PAC) FCPA enforcement settlement for $280 million with the Justice Department and the Securities and Exchange Commission contains a number of important lessons learned. ...more

The Volkov Law Group

Panasonic Avionics Pays $280 Million to Resolve FCPA Offenses in Middle East and Asia (Part I of II)

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As the nattering nabobs of negativism continued to claim that FCPA enforcement was on the decline, the Justice Department and the SEC settled a major FCPA enforcement action with Panasonic Avionics (PAC), a subsidiary of...more

Thomas Fox - Compliance Evangelist

Panasonic FCPA Enforcement Action: Part III – A 20% Discount

We continue our exploration of the Foreign Corrupt Practices Act (FCPA) enforcement action involving Panasonic Avionics Corporation (PAC) and its parent Panasonic Corporation (Panasonic)....more

Thomas Fox - Compliance Evangelist

Panasonic FCPA Enforcement Action: Part II – The Bribery Schemes

We continue our exploration of the Foreign Corrupt Practices Act (FCPA) enforcement action involving Panasonic Avionics Corporation (PAC) and its parent Panasonic Corporation (Panasonic). Today, I want to review the bribery...more

The Volkov Law Group

Criminal Enforcement Against Senior Executives: The Fish Rots from the Head

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The compliance community is well aware of the risks in the C-Suite. As you move up the corporate ladder, the level of risk from executive misconduct increases. A rotten executive can quickly bring down a company, destroy...more

The Volkov Law Group

The “New” Face of Corporate Misconduct

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As we look across the corporate governance landscape and focus on the spikes of corporate scandals, I started to wonder if there was any pattern or trend to the nature of corporate scandals....more

Thomas Fox - Compliance Evangelist

Godspeed to John Glenn and Failures at Deloitte

Last week, I paid tribute to Greg Lake. It turned out that the first full week of December was the final week for several important, if not seminal, figures. So this week I will pay homage to those who have left us, today I...more

The Volkov Law Group

DOJ and SEC Collect $22 Million from LAN Airlines for Conduct in Resolving Labor Dispute

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Last week, the Justice Department and the SEC announced parallel FCPA settlements totaling $22 million in fines, penalties and disgorgement against LAN Airlines, a Chile-based airline, for conduct in resolving a labor dispute...more

Thomas Fox - Compliance Evangelist

The BHP Case and Enforcement of The FCPA’s Internal Controls Provision

Ed. Note-today we have a guest post from Jean-Michel Ferat ,CPA, CFF is a Managing Director in the Washington D.C office of the Claro Group around his views on the BHP Billiton enforcement action. Much has been made in...more

Carlton Fields

Anti-Money Laundering Trends: Facts, Findings, and Lessons Learned

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Increased anti-money laundering (AML) regulation enforcement by federal and state agencies in recent months should have financial institutions across the country reviewing and strengthening their in-house AML policies and...more

The Volkov Law Group

The Relationship Between Sarbanes-Oxley And FCPA Compliance

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Ten years ago, Sarbanes-Oxley was the focus of compliance and corporate governance reform. Sarbanes-Oxley was enacted in response to major corporate scandals involving financial reporting fraud and accounting...more

Ballard Spahr LLP

The SEC’s Renewed Focus on Financial Reporting and Accounting Fraud

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In several recent public speeches, the Securities and Exchange Commission (SEC) has announced a renewed focus on financial reporting and accounting fraud, vowing to devote substantial resources to enforcement activities in...more

Katten Muchin Rosenman LLP

SEC Scores in Accounting Fraud Suit Against BankAtlantic Corp. and Former CEO

On October 10, a Florida federal judge granted the Securities and Exchange Commission’s motions for partial summary judgment against BankAtlantic (now BBX Capital Corp.) and its former CEO and chairman Alan Levan, finding...more

The Volkov Law Group

SEC “Refocuses” On Accounting Fraud

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It is almost a government rite of passage – when a new leader takes the reins, the chessboard has to be reorganized to reflect the new leader’s “new priorities.” When it comes to the SEC, and the new Chairwoman Mary Jo...more

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