The Justice Insiders Podcast - The Ever-Expanding Net: Corporate Compliance in an Era of Increasing Trade Sanctions and Restrictions
False Claims Act Insights - Are All Healthcare “Kickbacks” Subject to FCA Liability?
Episode 333 -- The Boeing Proposed Plea Agreement
DOJ’s New Self-Disclosure Policy and Corporate Whistleblower Awards Pilot Program
False Claims Act Insights - Assessing the Fallout from a Thermonuclear FCA Verdict
FCPA Survival Guide - Step 8 - Investing in Compliance
Exploring the AI and Crypto Intersection
The Justice Insiders Podcast: Jarkesy’s Implications for the Administrative State
The Presumption of Innocence Podcast: Episode 41 - The Dynamics of Decision-Making: Psychology and the Criminal Justice System
INTERPOL and Child Kidnapping Cases. What are INTERPOL’s Abilities and Limitations?
False Claims Act Insights - Eureka! Government Investigators Seek Out Research Misconduct
The Justice Insiders Podcast - AI-Washing: Everything Old Is New Again
The CFPB and State AGs Act Jointly Against Online Educational Company
Will the U.S. Have a GDPR? With Rachael Ormiston of Osano
Episode 328 -- Sanctions Enforcement Risks and Redlines
FCPA Survival Guide: Step 3 - Extensive Remediation
Episode 324 -- Third-Party Risks and Sanctions Compliance
Compliance Tip of the Day – Compliance Lessons from the Albemarle FCPA Enforcement Action
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
On May 30, 2024, the US Department of Labor (DOL) filed a complaint in the Middle District of Alabama against a US subsidiary of Korean carmaker Hyundai seeking to hold Hyundai liable for child labor violations alleged to...more
The SFC exercises its powers to order the suspension of trading in shares in a listed company to protect investors’ interests. On 15 April 2024, The Stock Exchange of Hong Kong Limited (SEHK) suspended trading in the...more
When it comes to OFAC sanctions violations, honesty is the best policy. Promptly and voluntarily disclosing violations upon their discovery can pay serious dividends. ...more
SEC enforcement actions against public companies and subsidiaries rose again in FY 2023, with 91 new actions filed, the third highest of any fiscal year in SEED. Although filings increased, total monetary settlements fell to...more
On April 29, 2021, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced two settlements of potential civil liability with two companies over their apparent violations of its regulations. The...more
On August 14, 2020, the US Department of Justice (the DOJ) issued its first Foreign Corrupt Practices Act (FCPA) Opinion Procedure Release in six years, which relayed that it did not intend to pursue an enforcement action...more
A recent US District Court for the District of Connecticut decision reveals the practical limits of the Foreign Corrupt Practices Act (FCPA) in cases involving foreign nationals, foreign conduct and complex multinational...more
Cardinal Health (“Cardinal”) agreed to pay the SEC $8.8 million for FCPA violations in China relating to its internal controls and books and records. Cardinal acknowledged facts relating to internal controls deficiencies and...more
The SEC announced charges against alcohol producer Diageo plc for failing to make required disclosures of known trends relating to the shipments of unneeded products by its North American subsidiary to distributors. Diageo...more
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
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
The Sweden-based telecommunications company, Ericsson, agreed to a pay a total of $1 billion (yes, billion with a “B”) for FCPA violations. Ericsson entered into settlement agreements with DOJ and the SEC. Ericsson agreed...more
Earlier this year the SEC’s Enforcement Division published its annual report, reviewing FY 2019 which ended on September 30, 2019. As in the past, the Report reviewed not just the statistics from the year but also the entire...more
On August 29, 2019, the Securities and Exchange Commission (“Commission” or “SEC”) agreed to resolve an enforcement action against Juniper Networks, Inc. (“Juniper” or the “Company”), a Silicon Valley-based cybersecurity and...more
On July 22, 2019, the United States Department of Justice (“DOJ”) and Securities and Exchange Commission (“SEC”) announced that they had resolved allegations of Foreign Corrupt Practice Act (“FCPA”) violations against...more
Initially, it would not seem that much was new or different about the Microsoft FCPA enforcement action but through this exploration, I think some clear lessons have emerge. The first is around internal controls. Here there...more
We continue our exploration of the TechnipFMC Foreign Corrupt Practices Act (FCPA) enforcement action by considering the actions taken by the company (or both separately before their merger) in response to their FCPA...more
On March 27, 2019, the Office of Foreign Assets Control (OFAC) announced a settlement agreement with US-based Stanley Black & Decker, Inc., (Stanley Black & Decker) and its foreign subsidiary, Jiangsu Guoqiang Tools Co., Ltd....more
Under the second year of the Trump Administration, the biggest story was the increase of corporate declinations one year after the DOJ adopted a permanent FCPA policy incentivizing self-disclosure, cooperation, and...more
The January 2019 FCPA Digest is an invaluable compendium of all FCPA-related developments in 2018, including US foreign bribery proceedings and criminal prosecutions, DOJ foreign bribery civil actions, SEC actions, DOJ...more
On Dec. 4, 2018, the New York Attorney General (AG) announced that media giant and AOL successor Oath Inc. (Oath), a subsidiary of Verizon Communications, Inc., agreed to pay nearly $5 million to settle charges that its...more
The Prudential Regulation Authority has announced that it has imposed financial penalties on two senior managers for failing to be open and cooperative about an enforcement action into the U.K. subsidiary of a Japanese bank...more
The civil settlement is one of the largest FCA settlements in recent years. The Department of Justice ("DOJ") recently announced that it agreed with AmerisourceBergen Corporation ("ABC") and several of its subsidiaries to...more
In the spring of last year, the Consumer Financial Protection Bureau (“CFPB”) filed an enforcement action against Ocwen Financial Corporation (“Ocwen”) and its subsidiaries for violation of mortgage servicing rules. The suit...more
On August 24, 2018, the US Court of Appeals for the Second Circuit in United States v. Hoskins rejected the government’s broad reading of the Foreign Corrupt Practices Act (FCPA) and ruled that a foreign national without ties...more