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
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
What happens when a major defense contractor faces scrutiny for ethics and compliance violations? In this episode of Corruption, Crime, and Compliance, Michael Volkov dives into the high-stakes world of corporate...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
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
You have to give the Justice Department credit — after two slow enforcement years, DOJ is starting off 2024 with a relative “bang;” first, DOJ reached a large settlement with SAP in January, and now, DOJ has reached a...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
FCPA trends often are relatively easy to describe and often overblown as a marketing technique by the usual cast of paparazzi suspects. (Self-proclaimed prognosticators that often push incorrect themes to promote business,...more
DOJ announced two recent FCPA settlements with U.K. based reinsurance brokers involving a long-running bribery scheme involving two Ecuadoran state-owned insurance companies. While DOJ has had a slow year in FCPA...more
As an employee in the technology or cryptocurrency industry, you hoped to put your skills to use behind a company that could make a real difference in the world. However, both tech companies and cryptocurrency companies...more
Rio Tinto, the global mining and metals company, agreed to pay the SEC $15 million to settle FCPA violations arising from an alleged bribery scheme involving a senior Guinean government official....more
The Department of Justice continues to respond to the compliance community’s concerns about the new certification requirement adopted as part of the Glencore FCPA enforcement action. DOJ has adopted this new requirement to...more
While we wait for the coming FCPA enforcement storm, DOJ and the SEC have quietly continued to rack up and resolve several enforcement actions....more
In its continuing aggressive FCPA criminal enforcement program, DOJ announced the indictment of two former Alstom executives and a former Marubeni executive with FCPA violations arising from a bribery scheme in Indonesia....more
The Foreign Corrupt Practices Act (“FCPA”) prohibits paying or offering bribes to foreign officials to obtain business advantage. In some instances, the paying or offering of bribes prohibited by the FCPA may involve multiple...more
Over the past several blog posts, I have been exploring the Airbus SE (Airbus) international anti-corruption settlement in some depth. One of the questions I have had and hopefully raised for readers is not why the overall...more
Last week, Airbus SE (Airbus) settled a long-standing corruption scandal by agreeing to enforcement actions in three countries; France, the United Kingdom and the US. The matter involved a massive, worldwide, long running...more
When reviewing a major enforcement case, I always ask two basic questions: What was the role of Board and senior management in the failure, and how did they fail to exercise proper oversight and ensure compliance?...more
The Justice Department has brought only a few enforcement actions that focus on FCPA and export control violations. Last year, Quad Graphics earned a declination for FCPA and OFAC violations. In 2013, Weatherford settled...more