Episode 345 -- Raytheon Pays $950 Million to Resolve Fraud, FCPA, ITAR and False Claims Act Violations
The ‘Long Arm’ of CIPA and Its Newfound Pen-Trap Claims
Episode 119 -- The Ericsson FCPA Settlement
On February 4, 2025, the Federal Communications Commission (FCC or Commission) released a Notice of Apparent Liability for Forfeiture (NAL) against voice service provider Telnyx LLC (Telnyx) for alleged violations of the...more
OFAC means what it says — in more ways than one. In a precedent setting case, OFAC brought its first enforcement action against an individual for violating the Global Magnitsky Sanctions Regulations....more
On December 23, 2024, the U.S. Court of Appeals for the Sixth Circuit ruled in Su v. KDE Equine, LLC that whether an employer willfully violated the Fair Labor Standards Act (FLSA) is a fact question best left to the jury. ...more
Bit Mining, formerly 500.com, was a doomed company from the beginning, When a CEO orchestrates a bribery scheme with the assistance of other senior executives, shareholders and the public have little chance of ensuring a...more
We should all admit something (among many things) — reading through factual statements of bribery offenses, the facts all start to meld together. Criminals are not as ingenuous or creative as they think, and the schemes they...more
Raytheon’s comprehensive settlement included FCPA violations and failures to make required disclosures to the Defense Department concerning fees and commissions. This portion of the settlement was filed in the Eastern...more
Raytheon Company (Raytheon) — a subsidiary of defense contractor, RTX (formerly known as Raytheon Technologies Corporation) — agreed to pay over $950 million to resolve the Justice Department’s investigations into: (i) a...more
With Gov. Gavin Newsom's signature in late September 2024, Senate Bill (SB) 707, the Responsible Textile Recovery Act of 2024 (the Act), made California the first state to adopt the Extended Producer Responsibility (EPR)...more
TD Bank’s $3 billion settlement included coordinated regulatory settlements with the Federal Reserve Board (“Federal Reserve”), The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”), and the...more
A new California law requires written contracts when engaging most solo independent contractors. The written contracts must contain certain types of information....more
In yet another reminder of the scope of Justice Department enforcement powers, and an important demonstration of the risks of non-compliance, the Justice Department and relevant banking agencies announced a $3 billion...more
Last week, representatives of the US government announced one of the largest sets of fines and penalties for failures in anti-money laundering ever laid down. It involved TD Bank N.A. and TD Bank US Holding Company. It was...more
We recently had a Foreign Corrupt Practices Act (FCPA) enforcement action that reminded me that everything old is new again in anti-corruption compliance. The Securities and Exchange Commission (SEC) FCPA enforcement action...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
Crypto Firms Announce New Products in Payments, Investments, Custody - A major U.S. digital asset management company recently announced the creation and public launch of its MakerDAO Trust, which “offers investors the...more
Violations of the federal Anti-Kickback Statute (the “AKS”) have long served as a basis for liability under the federal False Claims Act (the “FCA”). Recently, however, there has been increasing uncertainty regarding how far...more
On June 3, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) announced the resolution of an administrative enforcement action brought against Airbus DS Government Solutions (“Airbus DSGS”)—a...more
A recently announced settlement with online alcohol addiction treatment service Monument Inc. demonstrates the Federal Trade Commission’s (FTC) continued focus on the use and disclosure of health data. The proposed settlement...more
The SEC has issued a controversial 886-page final rule imposing climate-related disclosure requirements on publicly traded companies, including banking organizations, which will require them to include certain climate-related...more
Effective February 13, 2024, the U.S. Department of Justice (DOJ) increased civil monetary penalties, for violations occurring after November 2, 2015, including those related to immigration....more
The Digital Markets Act (DMA) regulation of September 14, 2022, along with the Digital Services Act (DSA) regulation, represents one of the major digital initiatives of the European Union. Gradually applicable since May 2,...more
Following an 8 week trial, a federal jury in Brooklyn has convicted Javier Aguilar on charges relating to the former Vitol trader’s violations of the Foreign Corrupt Practices Act. He faces up to 30 years in prison. Aguilar...more
On March 13, 2024, the EU AI Act received its final assent from the EU Parliament with 523 votes in favor, 46 against and 49 abstentions, bringing it one step closer to adoption. Minor linguistic changes are still to be...more