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White Collar Crimes Fraud

SCCE Compliance and Ethics Institute – Eugene Soltes and How Compliance Programs Works

by Thomas Fox on

The first full day of the SCCE 2017 Compliance and Ethics Institute (CEI) featured a talk by Eugene Soltes, an associate professor at Harvard Business School and author of “Why They Do It”. For this book Soltes spent over...more

Dieselgate: Bringing a Face to Scandal Impacting Volkswagen Owners

A Volkswagen manager pleaded guilty to conspiracy and violating the Clean Air Act and could get seven years in prison. A Volkswagen engineer who agreed to testify against the Volkswagen manager was sentenced to three years in...more

For the Benefit of Mr. Kite – Fiction in the World of Quality Assurance

by Thomas Fox on

The basics were laid out by Peter Wells and Emiko Terazono in a Financial Times (FT) article entitled “Kobe Steel scandal hits Boeing, Toyota and Nissan”. The Japanese company admitted it had falsified “inspection data on an...more

The Fraud Triangle, Rationalizations and Compliance Programs

by Thomas Fox on

The fraud triangle is well-known to most compliance practitioners. Its third sides are pressure, opportunity and rationalization. When these three factors converge, there is danger of an ethical lapse which could lead to...more

Midnight Cruising with Steely Dan – Finding Patterns in Raked Leaves

by Thomas Fox on

Last Friday on September 1, I began a new installment of my year-long podcast series, where each month I focus on a different compliance topic. This month, I am focusing on innovation in compliance....more

Your Daily Dose of Financial News

by Robins Kaplan LLP on

Is the SEC officially on record with a warning about the viability of unregulated ICOs? It is. Is that stopping start-ups from creating and selling new virtual currencies at a torrid pace? It is not....more

Court Dispenses With Fraud Defense Based on Gumball Victims’ Disclaimers

The Chicklets and Runts vending machine at your local car repair shop last decade may have been one piece of a fraudulent enterprise that ensnarled roughly 7,000 victims. As CEO of Vendstar, Defendant Edward (“Ned”) Weaver...more

White Collar Watch (July 2017 • Vol 1, Issue 2)

by Blank Rome LLP on

Welcome to the summer edition of Blank Rome’s White Collar Watch. In a world that seems to bring new challenges daily—such as the global cybersecurity attacks that were launched in late June—this newsletter is designed to...more

What Happened in Oslo Shouldn’t Stay in Oslo - Corporate Compliance Insights

Fresh on the heels of the Anti-Korrupsjons+Konferansen in Norway, Richard Bistrong offers a look inside the conference and details some of the key takeaways. Originally published in Corporate Compliance Insights....more

Grand Jury Indicts Startup Founder Isaac Choi – Implications for Silicon Valley

by Fenwick & West LLP on

On June 7, the U.S. Department of Justice arrested Isaac Choi, the founder and former chief executive of the Silicon Valley startup, WrkRiot, on wire fraud charges. A San Jose, California grand jury had indicted Choi under...more

Preparing for an Investigation

by Thomas Fox on

The Department of Justice’s (DOJ) Evaluation of Corporate Compliance Programs (Evaluation), under Prong 7 Confidential Reporting and Investigation asks the following: Properly Scoped Investigation by Qualified Personnel – How...more

Bond Fraud Trial Shows Need to Scrutinize Municipal Revenue Generation

Ramapo, N.Y., Town Supervisor Christopher St. Lawrence is in the middle of a multi-week trial on two dozen securities fraud charges stemming from municipal bond issuances and accounting practices in Ramapo, a Rockland County...more

Individual Accountability in AML Cases

by Ballard Spahr LLP on

This post discusses individual liability in AML/BSA enforcement, which is an area of increasing attention. Indeed, according to public statements by the government, individual liability is the focus of enhanced scrutiny...more

English Court Questions the Application of Litigation Privilege in Criminal Investigations

On 8 May 2017, the English High Court of Justice handed down judgment in The Director of the Serious Fraud Office v. Eurasian Natural Resources Corporation Ltd,1 which could significantly limit the application of litigation...more

First 100 Days of the Trump Administration and The FCPA – Same As It Ever Was

by Thomas Fox on

Over the weekend, we had the first 100 days of the Trump administration. To commemorate this constructed time for review of any new administration I gathered the Everything Compliance podcast panel of Mike Volkov, Jay Rosen,...more

Termination of a Third-Party – Planning Can Reduce the Pain

by Thomas Fox on

The European concern Airbus has been in the news recently for corruption issues. According to an article in the Financial Times (FT), entitled “Airbus sued by middlemen fired following fraud inquiry”, its annual report lists...more

Brazilian Corruption Scandals Continue

by Thomas Fox on

The stench of corruption continues to bedevil Brazil, even as the clean-up initiated with Operation Car Wash is ongoing. This time, allegations of bribery and corruption have reached one of Brazil’s most prestigious exports,...more

Your Daily Dose of Financial News

by Robins Kaplan LLP on

White Collar Watch dates itself considerably with its Perry Mason allusion, but its bigger point is an interesting one–good luck finding a true “gotcha” moment when dealing with what are “quintessentially offenses of the...more

Understanding the New DOJ Guidance: Part 1 – Tone at the Top

In February, the Department of Justice’s Fraud Section offered a new perspective on what the government expects in a compliance program in the form of a series of questions that companies should be prepared to answer about...more

Justice Department Reveals How It Evaluates Corporate Compliance Programs

by Holland & Knight LLP on

The U.S. Department of Justice (DOJ) Fraud Section recently published its "Evaluation of Corporate Compliance Programs" that lists 1) the topics it explores and 2) the questions it asks when it assesses the effectiveness of a...more

Return to Sender: Aéropostale Employee’s Fraud Convictions Affirmed, But Restitution Order Sent Back for Recalculation

Aéropostale is known by many as a staple of adolescent wardrobes and shopping-mall standard. But as a patsy for kickback schemes? In United States v. Finazzo, 14-3213-cr, 14-3330-cr (Droney, J., joined by Judges Sack and...more

New Attorney General Issues Guidance on Corporate Compliance Programs

by Foley & Lardner LLP on

The US Department of Justice (DOJ) Fraud Section has published new guidance for corporate entities on corporate compliance programs. The guidance, titled, “Evaluation of Corporate Compliance Programs” (Compliance Program...more

When Will Shareholders Force Boards to Do Compliance?

by Thomas Fox on

Today we honor one of the most iconic moments of World War II (WWII) and one of the most famous photographs of all time, that of the Marines raising the US flag on Mount Suribachi on the island of Iwo Jima. Marine...more

First ‘Trial of the Century’ and the SQM FCPA Enforcement Action – Part II

by Thomas Fox on

Today I conclude my two-part series on the recent Foreign Corrupt Practices Act (FCPA) enforcement action involving the Chilean chemicals and mining company Sociedad Química y Minera de Chile (SQM), which agreed to pay a...more

DOJ Fraud Section Unveils Blueprint for Assessing Corporate Compliance Programs

by White & Case LLP on

In the year and a half that has transpired since the DOJ's Fraud Section retained a compliance consultant to assist prosecutors' evaluation of compliance programs, compliance officers, general counsels and white-collar...more

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