News & Analysis as of

Corruption Cease and Desist Orders

The Volkov Law Group

Dubai Bank Pays $100 Million to Resolve Sanctions Violations with DFS, OFAC and Federal Reserve

The Volkov Law Group on

Mashreqbank, based in Dubai, agreed to pay $100 million to the New York Department of Financial Services, the Federal Reserve, and the Office of Foreign Asset Control for violation of the now-repealed Sudan Sanctions...more

Porter Hedges LLP

Credit Suisse Settlement Carries Broader Lessons about Reputational Risk

Porter Hedges LLP on

On October 19, 2021, the U.S. Securities and Exchange Commission (“SEC”) announced that Credit Suisse Group AG (Credit Suisse) agreed to pay $100 million to the SEC (among other penalties to other agencies) for violations of...more

Thomas Fox - Compliance Evangelist

J&F – The SEC Order

Today, I continue a multi-part exploration of one world’s largest anti-corruption enforcement actions, the J&F Investimentos SA (J&F) matter. It involved huge fines and penalties in both Brazil and the United States. Of...more

Thomas Fox - Compliance Evangelist

The Herbalife FCPA Enforcement Action: Part 4 – Final Thoughts

We are the end of my multi-part exploration of the Herbalife Nutrition Ltd (Herbalife) Foreign Corrupt Practices Act (FCPA) enforcement action with both the Department of Justice (DOJ) and Securities and Exchange Commission...more

Thomas Fox - Compliance Evangelist

The Herbalife FCPA Enforcement Action: Part 3 – Penalty Calculation and No Monitor

Herbalife Nutrition Ltd (Herbalife) recently concluded a long running Foreign Corrupt Practices Act (FCPA) enforcement action with both the Department of Justice (DOJ) and Securities and Exchange Commission (SEC). Herbalife...more

Thomas Fox - Compliance Evangelist

The Herbalife FCPA Enforcement Action: Part 2 – Bribery Schemes and Numbers

Herbalife Nutrition Ltd (Herbalife) recently concluded a long running Foreign Corrupt Practices Act (FCPA) enforcement action with both the Department of Justice (DOJ) and Securities and Exchange Commission (SEC). Herbalife...more

Thomas Fox - Compliance Evangelist

Recidivist Eni: Corruption, Controls and Books and Records

Eni S.p.A (Eni) joined the two-time Foreign Corrupt Practices Act (FCPA) loser ranks last week when it agreed to a Cease and Desist Order (Order) with the Securities and Exchange Commission (SEC) for violations of the...more

Thomas Fox - Compliance Evangelist

Cardinal Health FCPA Enforcement Action: High Risk Business Relationships

Cardinal Health Inc. (Cardinal) settled its Foreign Corrupt Practices Act (FCPA) matter with the Securities and Exchange Commission (SEC) last week. According to the SEC Press Release, Anita B. Bandy, Associate Director in...more

Thomas Fox - Compliance Evangelist

Wells Fargo Settlement: Part 1 – It’s Even Worse Than Imagined

I did not think that the Wells Fargo fraudulent accounts scandal could get worse for the bank. Boy was I wrong. Last week, in a Press Release, the Department of Justice (DOJ) announced a that Wells Fargo & Company and its...more

Thomas Fox - Compliance Evangelist

Top SEC Enforcement Actions from 2019

Yesterday, I considered five Department of Justice (DOJ) Foreign Corrupt Practices Act (FCPA) enforcement actions. Today, I want to look at key FCPA enforcement actions by the Securities and Exchange Commission (SEC)....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

Barclays – Back to the Basics

This week I am considering the recent spate of Foreign Corrupt Practices Act (FCPA) enforcement actions brought by the Securities and Exchange Commission (SEC) at the close of its fiscal year. Last week saw several...more

Thomas Fox - Compliance Evangelist

Quad/Graphics – The Sham-ness of It All

This week I will be considering the recent spate of Foreign Corrupt Practices Act (FCPA) enforcement actions brought by the Securities and Exchange Commission (SEC) at the close of its fiscal year. Last week saw several...more

Thomas Fox - Compliance Evangelist

Two Tickets to Paradise and the Thiruvengadam FCPA Settlement

We got a fair bit more clarity on the Cognizant Technologies Solutions Corporation (“Cognizant”) Foreign Corrupt Practices Act (FCPA) last week, when Sridhar Thiruvengadam, the Chief Operating Officer (COO) agreed to settle...more

Thomas Fox - Compliance Evangelist

Juniper Networks FCPA Enforcement Action-Speak Sternly and Enhance Controls

Last week Juniper Networks, Inc. (JNPR) resolved their long-standing Foreign Corruption Practices Act (FCPA) enforcement action by settling with the Securities and Exchange Commission (SEC) via a Cease and Desist Order...more

Thomas Fox - Compliance Evangelist

Walmart FCPA Enforcement Action: Part 2 – The Bribery Schemes

The long-awaited Walmart Inc. (Walmart) Foreign Corrupt Practices Act (FCPA) enforcement action was announced last week. This massive case came in with multiple documents, a long list of instances of bribery and corruption, a...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

Major Sporting Event Hospitality: Part II – Lessons Learned

Yesterday, I considered the recently announced Securities and Exchange Commission (SEC) Foreign Corrupt Practices Act (FCPA) enforcement action against Telefônica Brasil S.A., Cease and Desist Order(Telefonica Order)....more

Thomas Fox - Compliance Evangelist

Fresenius FCPA Enforcement Action: Part V – Lessons Learned on Investigative Steps and Remedial Actions

We continue this multipart exploration of the recent announcement of the Fresenius Medical Care AG & Co. KGaA (FMC) Foreign Corrupt Practices Act (FCPA) enforcement action....more

Thomas Fox - Compliance Evangelist

A Great Day in Harlem and Customer Complicity in Funding Bribes

Last year (on Monday) I began a two-part blog series on the final two Foreign Corrupt Practices Act (FCPA) of 2018. On Monday, we considered the Polycom, Inc. FCPA enforcement action and today we consider the enforcement...more

Holland & Knight LLP

Petrobras Agrees to Pay More Than $1.8 Billion for Facilitating FCPA Violations

Holland & Knight LLP on

• Four years ago, Brazilian authorities began Operation Car Wash, a wide-ranging and still ongoing corruption and money laundering investigation that has spanned 11 countries. • The fallout continues with a recent U.S....more

Thomas Fox - Compliance Evangelist

The NPA; The Petrobras FCPA Enforcement Action: Part III

This blog post concludes my multi-part exploration of the Petróleo Brasileiro S.A. – Petrobras (Petrobras) Foreign Corrupt Practices Act (FCPA) enforcement action. Today we consider the stunning result achieved by Petrobras –...more

Thomas Fox - Compliance Evangelist

Farewell to Marty Balin; the Petrobras FCPA Enforcement Action: Part I

This blog post will begin a multi-part exploration of the Petróleo Brasileiro S.A. – Petrobras (Petrobras) Foreign Corrupt Practices Act (FCPA) enforcement action. The action was a stunning reminder of the costs of endemic...more

Thomas Fox - Compliance Evangelist

Ed King, Two Great Songs and Legg Mason

King’s back story of starting with the great psychedelic band Strawberry Alarm Clock and then moving to the Southern rockers Lynyrd Skynyrd, informs today’s blog post on the Legg Mason, Inc. (LM) Securities and Exchange...more

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