News & Analysis as of

Compliance Department of Justice (DOJ) Settlement Agreements

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 -
Health Care Compliance Association (HCCA)

In This Month’s E-News: August 2024

The Food and Drug Administration (FDA) has given Massachusetts Institute of Technology (MIT) 15 days from receipt of its June 21 warning letter to elaborate on corrective actions to address violations of federal requirements...more

American Conference Institute (ACI)

[Event] The Brazil Summit on Anti-Corruption, Integrity & ESG - May 22nd - 23rd, São Paulo, Brazil

Hosted by American Conference Institute, the 14th Annual Summit on Anti-Corruption, Integrity & ESG returns to Brazil for another groundbreaking year to discuss the current high-stakes dilemmas impacting your organization....more

BakerHostetler

Employers Beware: Broad Confidentiality and Severance Clauses May Violate Whistleblower Protection Laws

BakerHostetler on

Employers should check their confidentiality and severance agreements for a common oversight that, for some, is becoming a costly error. Recent enforcement activity by the Securities and Exchange Commission (SEC) of Rule...more

The Volkov Law Group

DOJ and SEC Secure $41 Million Settlement from Brazilian Airline for FCPA Violations (Part I of II)

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The Department of Justice and the Securities and Exchange Commission reached a $41 million settlement with GOL Linhas Aéreas Inteligentes S.A. (“GOL”) to resolve criminal and civil foreign bribery charges....more

Hanzo

[Webinar] Luminary Series: How Recent Regulatory Rulings Are Shaping Compliance - July 28th, 1:00 pm ET

Hanzo on

When it comes to ensuring enterprise data is safe, understanding recent rulings from different regulatory bodies and how they affect your organization is a vital first step, followed by reasonable measures to further...more

The Volkov Law Group

The Glencore Settlement: Lessons Learned (Part V of V)

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The Justice Department has resumed FCPA enforcement with a bang.  The new enforcement approach has been unveiled and the message for CCOs and corporate business leaders is clear — anti-corruption compliance should be a...more

The Volkov Law Group

DOJ Puts its New Stamp on FCPA Settlements: Unraveling the Glencore FCPA Settlement (Part II of V)

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The Justice Department has been promising a new, more aggressive approach to FCPA enforcement.  DOJ officials have made statements to that effect on numerous occasions.  The Biden Administration touted its elevation of the...more

The Volkov Law Group

Allianz Global Hit With $6 Billion Fine And Portfolio Manager Indicted in Connection with Million-Dollar Fraud Scheme

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In a blockbuster settlement, DOJ unleashed its full power against Allianz Global and key portfolio managers responsible for a massive, long running fraud scheme involving a series of private investment funds managed by...more

The Volkov Law Group

Stericycle DOJ and SEC FCPA Settlement: Lessons Learned (Part III of III)

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The Stericycle FCPA case is yet another example of a complete culture and compliance breakdown.  As I often repeat myself, there is no more important control than an ethical culture.  When a culture veers into the unethical...more

Health Care Compliance Association (HCCA)

Hospital Settles FCA Case Filed by CO Over Modifiers; Make Sure People ‘Feel Heard’

Report on Medicare Compliance 30, no. 32 (September 13, 2021) - John Peter Smith (JPS) Hospital in Fort Worth, Texas, agreed to pay $3.3 million to settle false claims allegations in a case with a hot risk area, a...more

Perkins Coie

DOJ’s First False Claims Act Settlement Against PPP Borrower Signals Robust Fraud Enforcement Ahead

Perkins Coie on

As the government revives its Paycheck Protection Program (PPP) with hundreds of billions of dollars in additional loans available to small businesses, there are fresh signs that government fraud investigations and...more

The Volkov Law Group

DOJ FCPA Settlement: J&F Investmentos’ Bribery Schemes (Part II of V)

The Volkov Law Group on

J&F’s Investmentos bribery scheme was pervasive and was coordinated with a senior Brazilian Finance minister and orchestrated through the use of United States banking.  The Brazilian official appears to be Guido Mantega, who...more

ArentFox Schiff

JPMorgan Chase DPA Provides Insight into Government’s Assessment of Compliance Programs

ArentFox Schiff on

On September 29, 2020, US authorities announced that they reached an agreement with JPMorgan Chase & Co. (JPMorgan Chase) to settle criminal charges related to two distinct years-long market manipulation schemes involving...more

Skadden, Arps, Slate, Meagher & Flom LLP

FTC and DOJ Enforcement Actions Highlight Scrutiny of Divestiture Orders Compliance

Recent enforcement actions by the Federal Trade Commission (FTC or Commission) and the Department of Justice (DOJ) demonstrate the agencies’ continued close scrutiny of merging parties’ compliance with divestiture orders....more

Dechert LLP

Global Private Equity Newsletter - Winter 2020 Edition: Private Equity Firms with Health Care Investments Should Protect...

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The Department of Justice (“DOJ”) on September 18, 2019, announced a $21.36 million settlement with compounding pharmacy Patient Care America (“PCA”), two PCA executives, and private equity firm Riordan, Lewis & Haden, Inc....more

Vinson & Elkins LLP

VOC Emissions from Upstream Oil and Gas Operations: EPA Kicks Off 2020 Clean Air Enforcement with Two Significant Settlements

Vinson & Elkins LLP on

Last week, the EPA announced two significant settlements for violations of the Clean Air Act relating to emissions of volatile organic compounds (“VOCs”) from upstream oil and gas production facilities. These enforcement...more

The Volkov Law Group

FCPA Predictions for 2020 (Part III of III)

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It is time to break out the crystal ball for FCPA 2020 Predictions.  In preparing for this, I always rely on my past admiration of Carnac the Magnificent....more

The Volkov Law Group

2019 FCPA Enforcement Highlights (Part II of III)

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In a record year, there are bound to be numerous interesting enforcement actions and principles.  I picked out a few to highlight....more

The Volkov Law Group

FCPA 2019: A Record Year in Enforcement and Compliance (Part I of III)

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Happy New Year!! In the FCPA arena, 2019 was a record year – in enforcement and compliance. Many continuing trends are becoming more than trends – meaning they are turning into established practices....more

Skadden, Arps, Slate, Meagher & Flom LLP

Ericsson Agrees To Pay Over USD $1 Billion To Settle FCPA Charges

On December 6, 2019, Telefonaktiebolaget LM Ericsson (Ericsson or the Company), resolved long-running investigations by the U.S. Department of Justice (DOJ) and the U.S. Securities and Exchange Commission (SEC) into the...more

The Volkov Law Group

Bumble Bee CEO Convicted of Participating in Price-Fixing Conspiracy

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Global companies are paying greater attention to criminal antitrust risks – and with good reason.  We often dwell on the impact to a company of a major FCPA investigation.  A global criminal antitrust investigation often in...more

Thomas Fox - Compliance Evangelist

Congrats to the Nats and the Jho Low Forfeiture Agreement

As reported by Byron Tau and Aruna Viswanatha in the Wall Street Journal (WSJ), “Jho Low, the businessman-turned-fugitive accused of masterminding a multibillion-dollar fraud involving Malaysia’s sovereign-wealth fund, agreed...more

The Volkov Law Group

TechnipFMC Settles FCPA Violations for $296 Million

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Last week, on June 25, 2019, TechnipFMC agreed to settle FCPA violations with the Justice Department for $296 million that occurred in Iraq and Brazil.  TechnipFMC was created in 2017 through the merger of Technip, a French...more

The Volkov Law Group

Justice Department Recalibrates Corporate Monitors and DOJ Compliance Position

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In a recent speech, Brian Benczkowski, the Assistant Attorney General for the Criminal Division outlined the Justice Department’s new policy governing imposition of a corporate compliance monitor. ...more

The Volkov Law Group

Four Current FCPA Enforcement Trends

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There are two distinct themes in FCPA enforcement – the first is consistency, i.e., that some enforcement actions are relatively consistent across the board and, in the last five to ten years, the FCPA caseload has been...more

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