Wicked Coin: The "Fat Leonard" Scandal
Navigating Civil Standing Requirements for Defense Success — RICO Report Podcast
Episode 330 – Halyna Senyk on Anti-Corruption Progress in Ukraine
Managing Corruption Risk in Latin America
The Presumption of Innocence Podcast: Episode 38 - A Blueprint for Compliance: The Fraud Pentagon Theory
Episode 323 - Carlos Villagran Discusses Rebuilding a Corporate Culture After a Crisis
The Presumption of Innocence Podcast: Episode 34 - A Conversation With Jesse Eisinger, Author of 'The Chickenshit Club: Why the Justice Department Fails to Prosecute Executives'
Episode 317 -- A Deep Dive into the Trafigura FCPA Settlement
What's Going on with FCPA?
Episode 316 -- DOJ Announces New Whistleblower Policy
RICO Vicarious Liability — RICO Report Podcast
Episode 313 -- The Coming Criminal Corporate Sanctions Enforcement Storm
RICO Damages — RICO Report Podcast
Corruption, Crime & Compliance: DOJ’s Shifting Approach to Recidivism and Self-Disclosure
Episode 305 -- Deep Dive into SAP FCPA Settlement
AGG Talks: Antitrust and White-Collar Crime Roundup - Developments in the Trump Indictments and Recent Supreme Court Issues
Episode 300 -- Deep Dive into DOJ FCPA Settlement with Two U.K. Reinsurance Companies for Bribery in Ecuador
AGG Talks: Antitrust and White-Collar Crime Roundup - Examining the Latest Updates in the Pending Criminal and Civil Litigation Against Trump
The EU Directive for Combatting Corruption
Episode 295 -- Deep Dive into the Albemarle DOJ and SEC FCPA Settlements
We continue our exploration of how CEOs and senior executives are uniquely positioned to drive home the importance of ethical behavior and adherence to compliance regulations. Today, we consider the humble email and how it...more
The U.S. Securities and Exchange Commission (“SEC”) recently instituted proceedings against Deere & Company (“John Deere”), a leading global manufacturer of agricultural and heavy machinery, for multiple violations of the...more
The Justice Department is encouraging companies to voluntarily disclose criminal violations — “Come in and confess” and DOJ offers promises of a declination. But even a declination comes with a requirement — the company has...more
In a recent development that has garnered significant attention in the compliance community, the U.S. Department of Justice (DOJ) declined prosecution of Boston Consulting Group, Inc. (BCG) for violations of the Foreign...more
Compliance professionals constantly seek to understand how systemic issues within corporate hierarchies can lead to severe consequences. The recent revelations about Bank of America’s (BoA) persistent workplace culture...more
As compliance professionals, it is imperative to not just address the symptoms of such crises but to dig deeper and identify the root causes. In this case, it’s clear that the root cause is a toxic corporate culture that...more
Last month, I wrote a blog post on the tone at the top, exemplified in Star Trek’s Original Series episode, Devil in the Dark. Based on the response, some passionate Star Trek fans are out there. I decided to write a series...more
While FCPA enforcement against companies has been relatively quiet this year, despite a strong beginning to the year — the SAP case for $220 million; and the Gunvor case for $661 million — DOJ has been pushing a number of...more
In 2023, the number of federal corporate prosecutions remained far below the 25-year average after two consecutive years of increases. ..The DOJ’s Fraud Section secured just $690 million in penalties across eight...more
DOJ is feeling the heat. Corporate criminal enforcement numbers are down. in fairness, DOJ has been pushing individual criminal enforcement as an effective deterrent to corporate misconduct. Criminal prosecutions, when done...more
On June 28, 2024, the Financial Crimes Enforcement Network released a notice of proposed rulemaking. The purpose of the proposed rule is to strengthen and modernize Anti-Money Laundering and Countering the Financing of...more
In a world where corporate integrity and accountability are more crucial than ever, the Department of Justice (DOJ) ‘s Whistleblower Pilot Program announcement marks a pivotal moment for compliance professionals. This...more
In its proposed Plea Agreement, the Department of Justice (DOJ) lays out the abject failures of Boeing which led the DOJ to conclude the underlying Deferred Prosecution Agreement (DPA) from 2021 has been breached. The DOJ...more
When it comes to corporate accountability and the often murky waters of compliance, few cases are as illustrative and significant as the ongoing litigation involving Boeing. Since the 737 MAX safety scandal erupted in 2021,...more
Boeing’s Plea Agreement includes two Separate Factual Statements — the January 7, 2021 DPA, which is discussed in a prior blog post, and a factual outline of Boeing’s breach of the original DPA, resulting in the current Plea...more
I recently spoke with the Foreign Corrupt Practices Act (FCPA) Handbook authors Robert Tarun and Peter Tomczak from Baker McKenzie for a two-part podcast episode. The depth of knowledge and experience in white-collar crime,...more
Listen to this conversation between Michael Volkov and Halyna Senyk in which they focus on Ukraine's anti-corruption efforts amidst the backdrop of its ongoing war with Russia. Halyna Senyk, an expert from the CEELI...more
A few years ago, a friend of mine was part of an organization that received complaints about one of its leaders, which led to questions about whether the leader should be fired. The organization debated internally about what...more
On May 30, 2024, following passage by the European Parliament in late April, the European Council officially adopted a set of rules that modernizes and harmonizes money laundering and terrorist financing (“AML/CFT”)...more
In its latest report, The 2024 Benchmark of Ethical Culture Report, LRN has focused on the critical issue of corporate culture. LRN is a pacesetter and the leader in reliable studies on complex ethics and compliance issues....more