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Compliance Goldman Sachs

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

Roger Ng, Former Goldman Sachs Banker, Sentenced to 10 Years’ Imprisonment For Role in 1MDB FCPA Scandal

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The end of the road for Roger Ng, the Goldman Sachs Investment Banker, who played a critical role in the Goldman Sachs 1 MDB Malaysia scandal, was not a pretty one.  District Judge Margo Brodie gave Ng a severe sentence of...more

The Volkov Law Group

The Ins and Outs of the Ghana Bribery Scheme (Part II of II)

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Each FCPA case provides valuable lessons in the mechanics of bribery schemes and the common techniques used by violators to secure funds and make illegal payments to foreign government officials.  Criminal violators often act...more

The Volkov Law Group

Goldman Sachs Official Indicted Over Ghana Bribery Scheme (Part I of II)

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Talk about a reminder of the past, Asante Berko, a former Executive Director in Goldman Sachs, recently was arrested in London on criminal FCPA charges arising from his involvement in a bribery scheme in Ghana....more

The Volkov Law Group

The Recurring Business Question — Increase Profits Versus Compliance with the Law?

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There is much to be learned from reviewing the wreckage of a major Justice Department enforcement action.  It is helpful to identify these themes, analyze the conduct and reasons for the violation, and identify helpful...more

The Volkov Law Group

The Curious Absence of Corporate Monitors

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In 2020, the Justice Department did not insist on the appointment of any independent compliance monitors.  The year before, in 2019, DOJ insisted on the appointment of three independent corporate monitors – MTS...more

The Volkov Law Group

The “Person” of the Year: Goldman Sachs

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Bear with me for a second, but remember Presidential Candidate Romney’s statement in 2011 that “Corporations are people.” Starting with that premise, my so-called “Person” of the Year award for 2020 goes to, drumroll . . ....more

The Volkov Law Group

2021 FCPA Predictions (Part IV of IV)

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Well, it is that time again.  I get to put on my Carnac the Magnificent Hat and offer my FCPA predictions for 2021. I should get a pass on my 2020 FCPA Predictions posting because no one could have anticipated the COVID-19...more

The Volkov Law Group

2020 Year in Review: Interesting Enforcement Actions (Part III of IV)

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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

The Volkov Law Group

2020 FCPA Review: Another Record Year for Enforcement (Part I of IV)

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The Justice Department and the Securities and Exchange Commission had another record year of enforcement.  In fact, the last four years of FCPA enforcement included two years of record enforcement – 2019 and 2020.  After...more

The Volkov Law Group

Goldman Sachs and the Economic Impact of Corruption

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The breadth of Goldman Sachs’ corruption in the recent DOJ and SEC FCPA enforcement action underscored the important global goal of reducing corruption.  It goes without saying – corruption has a pernicious impact on economic...more

Thomas Fox - Compliance Evangelist

Compliance into the Weeds: The Goldman Sachs FCPA Enforcement Action

Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt and Tom go into the weeds to...more

The Volkov Law Group

Lessons Learned from the Goldman Sachs FCPA Enforcement Settlement (Part III of III)

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Goldman Sachs has a new leadership role – unfortunately, it is for corruption.  It would be a serious mistake to characterize or describe the Goldman corruption scheme as the result of a few, bad actors.  Instead, Goldman...more

The Volkov Law Group

Goldman Sachs’ Lucrative and Wide-Ranging Corrupt Scheme (Part II of III)

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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

The Volkov Law Group

Goldman Sachs Settles Massive 1MDB Bribery Case and Agrees to Pay Nearly $3 Billion (Part I of III)

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The Justice Department finally closed out its investigation of Goldman Sachs’ massive bribery scheme involving Malaysia’s 1MDB fund.  The case is now the largest in US FCPA history (based on its payment to DOJ and related US...more

Thomas Fox - Compliance Evangelist

Everything Compliance-Emergency Video Podcast on the Goldman Sachs FCPA Settlement

In this first live recording of Everything Compliance, an abbreviated crew of Matt Kelly, Jay Rosen and Tom Fox provide their initial thoughts and questions on the Goldman Sachs 1MDB FCPA settlement....more

Thomas Fox - Compliance Evangelist

Daily Compliance News: July 25, 2020-the Goldman Settles edition

Today, we dedicated the entire episode of the Daily Compliance News for July 25 to the settlement by Goldman Sachs to Malaysia over its role in the 1MDB scandal....more

Society of Corporate Compliance and Ethics...

1MDB scandal ringleader found to have ties to Kuwaiti sheikh

Report on Supply Chain Compliance 3, no. 13 (June 25, 2020) - Jho Low, the alleged mastermind behind the looting of Malaysia’s sovereign wealth fund, 1Malaysia Development Berhad, has been using his connections to Kuwaiti...more

The Volkov Law Group

SEC Charges Ex-Goldman Investment Banker for FCPA Bribes in Ghana Power Project

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Last week, the Securities and Exchange Commission (“SEC”) filed charges against Asante Berko, a former Goldman Sachs executive with bribery of foreign government officials in Ghana.  Goldman Sachs discovered and stopped the...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

Society of Corporate Compliance and Ethics...

United States reaches settlement with Malaysian fugitive Jho Low over $700 million in assets

CEP Magazine (January 2020) - The U.S. Department of Justice announced[1] a settlement of a civil forfeiture case against Low Take Jho, known as Jho Low, regarding assets allegedly bought with funds stolen from the...more

Robins Kaplan LLP

Financial Daily Dose 12.20.2019 | Goldman nearing $2B deal with DOJ to resolve 1MDB scandal claims

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Goldman Sachs is reportedly in negotiations with federal prosecutors to resolve claims about its role in the Malaysian 1MDB scandal for upwards of $2 billion. A settlement—which “could include a guilty plea from Goldman’s...more

Thomas Fox - Compliance Evangelist

Frosty the Snowman, the Eyes of Dr. Eckleburg and Leissner – Lessons Learned

I thought Frosty was a good analogy to consider the disgraced Goldman Sachs Group Inc.’s former partner Tim Leissner, as he is certainly back again. Yesterday, I begin a two-part blog post series on Leissner’s settlement with...more

Thomas Fox - Compliance Evangelist

The Grinch, Tim Leissner and the SEC – The Schemes

The Grinch is certainly a title that could be an allegory with disgraced Goldman Sachs Group Inc.’s former partner Tim Leissner about now. He was the lead Goldman Sachs banker who facilitated the firm’s work on bond offerings...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

Robins Kaplan LLP

Financial Daily Dose 9.5.2019 | Top Story: YouTube Fined $170 Million for Violating Kids’ Privacy Law

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Google will pay a “record $170 million fine and make changes to protect children’s privacy on YouTube” as part of a deal it reached this week with the FTC and NY AG’s office, both of whom had accused YouTube of “violating the...more

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