News & Analysis as of

Foreign Subsidiaries Settlement

The Volkov Law Group

C.H. Robinsom Settles with OFAC for $257,690 to Resolve Iran and Cuba Sanctions Violations

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C.H. Robinson International Inc. (CHR), a Minnesota-based global transportation and logistics company, has agreed to pay $257,690 to settle civil liability for 82 apparent violations of sanctions against Iran and Cuba...more

Foley Hoag LLP

The Voluntary Disclosure Landscape After Microsoft’s Settlements with BIS and OFAC and the Issuance of the Axelrod Memorandum

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On April 6, 2023, Microsoft Corporation (“Microsoft”) agreed to pay $3.3 million to the Department of Commerce’s Bureau of Industry and Security (“BIS”) and the Department of the Treasury’s Office of Foreign Assets Control...more

Kelley Drye & Warren LLP

Takeaways from OFAC’s $4.1 Million Settlement with Berkshire Hathaway

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This week, the Office of Foreign Assets Control (OFAC) announced a settlement agreement with Berkshire Hathaway Inc. involving apparent violations of the U.S. embargo on Iran by a subsidiary in Turkey. Under the agreement,...more

Vinson & Elkins LLP

After Soaring Settlement, SFO Propels Corruption Charges Against Airbus Subsidiary

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Mere months after Airbus entered into a record-breaking, nearly $4 billion resolution with the U.S., U.K., and France to settle foreign bribery allegations, the U.K.’s Serious Fraud Office (“SFO”) moved on July 30, 2020, to...more

Haug Partners LLP

Don’t Get Caught In the Conflict: U.S. Versus Brazilian IP Transfer Pricing Rules

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During a 2019 Tax Executives Institute conference in Washington, D.C., the Commissioner of the U.S. Internal Revenue Service (IRS), Charles Rettig, proclaimed, “[I am] not a commissioner who believes that the IRS loses...more

McDermott Will & Emery

Despite Appeals Win, Google Agrees To Eur 1B Settlement To Avoid Criminal Prosecution

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The Paris Court of Appeal affirmed that Google Ireland does not have a French permanent establishment in a high-profile tax controversy over a double Irish arrangement. But with independent criminal proceedings for tax...more

Burr & Forman

Walmart FCPA Settlement Shines Light On Corporate Compliance Programs

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June 20, 2019 – Walmart (NYSE: WMT) and its subsidiary, WMT Brasilia, agreed to a combined criminal penalty and disgorgement of $282M, together with WMT’s criminal guilty plea and undertakings in an NPA, to reach a global...more

WilmerHale

OFAC Crystallizes Expectations for Sanctions Compliance

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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

Bass, Berry & Sims PLC

OFAC Sanctions: No Entity Too Small or Too Far for Enforcement

Bass, Berry & Sims PLC on

- Canadian bank pays penalties for U.S. dollar transactions involving Cuba and Iran - Bank receives Finding of Violation – but no penalty – for violations by European subsidiaries - Disclosure and cooperation...more

Blank Rome LLP

SEC FCPA Enforcement Action against Goodyear and Investigation of Mondelez International Provide Valuable Lessons for U.S....

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Action Item: The Securities and Exchange Commission’s enforcement action against Goodyear Tire & Rubber Company and its investigation of Mondelez International provide key lessons to U.S. companies seeking to acquire foreign...more

Morrison & Foerster LLP

With No Civil Penalty, Goodyear FCPA Settlement Highlights Benefits of Cooperation and Remedial Actions

The Securities & Exchange Commission (“SEC”) announced last week that it charged The Goodyear Tire & Rubber Company (“Goodyear”) with violating the Foreign Corrupt Practices Act (“FCPA”), and that Goodyear agreed to pay more...more

The Volkov Law Group

Reminders from the Goodyear FCPA Settlement

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FCPA settlements carry with them a basket of compliance and enforcement lessons. The recent Goodyear settlement with the SEC for $16 million carries some important compliance and strategic reminders for ethics and compliance...more

Thomas Fox - Compliance Evangelist

FCPA Compliance and Ethics Report-Episode 122-with Matt Kelly on Alstom, Avon and Petrobras

In this episode, Compliance Week Editor-in-Chief Matt Kelly and I discuss the Avon and Alstom FCPA enforcement actions and then take a look at the ongoing Petrobras corruption scandal and what it means for Brazil. ...more

Thomas Fox - Compliance Evangelist

The Avon FCPA Settlement – Part III

Today I conclude my 2014 blog posts with a final look at the Avon Foreign Corrupt Practices Act (FCPA) enforcement action. Before getting to the key lessons that a compliance practitioner may draw from this enforcement...more

The Volkov Law Group

Three Blind Mice And The HP FCPA Settlement

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The HP FCPA settlement was not your run-of-the-mill enforcement action. The blogosphere has been filled with different analyses and interpretations. Client alerts have been taking shots at coming up with original ideas and...more

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