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White Collar Crimes Securities and Exchange Commission (SEC) Internal Controls

The Volkov Law Group

John Deere Reaches $9.9 Million Settlement with SEC over FCPA Violations

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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

Steptoe & Johnson PLLC

New York Federal Court Refuses to Extend Accounting Controls Requirements to Cybersecurity Controls

Section 13(b)(2)(B) of the Securities Exchange Act of 1934 requires public companies to “devise and maintain a system of internal accounting controls.” In a recent opinion, a New York federal court rejected the Securities...more

Skadden, Arps, Slate, Meagher & Flom LLP

Takeaways From the Dismissal of SEC Claims Against SolarWinds and Its CISO

The U.S. District Court for the Southern District of New York has dismissed many of the Securities and Exchange Commission’s (SEC’s) claims against software development company SolarWinds and its chief information security...more

Thomas Fox - Compliance Evangelist

Ten Top Lessons from Recent FCPA Settlements-Lesson No. 9, Internal Controls

Over the past 15 months the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) has made clear through three Foreign Corrupt Practices Act (FCPA) enforcement actions and speeches, their priorities in...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for November 2023

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Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption law and enforcement developments from the past...more

Skadden, Arps, Slate, Meagher & Flom LLP

SEC Enforcement Division Director Clarifies Approach to Compliance Officer Liability

In a speech on October 24, 2023, the director of the Securities and Exchange Commission’s (SEC’s) Enforcement Division, Gurbir Grewal, described the scenarios in which the commission would bring an enforcement action against...more

Thomas Fox - Compliance Evangelist

Albemarle FCPA Enforcement Action: Part 4 – Internal Control Failures

Albemarle Corporation (Albemarle), recently agreed to pay more than $218 million to resolve investigations by the U.S. Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) into violations of the...more

The Volkov Law Group

VMware pays SEC $8 Million for Misleading Financial Reporting

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The Securities and Exchange Commission’s bread-and-butter enforcement actions focus on accounting fraud.  The SEC has a long history in uncovering fraudulent financial reporting schemes.  In the early 2000s, Wall Street was...more

The Volkov Law Group

KT Corp. Settles SEC FCPA Case for $6.3 Million (Part I of III)

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The SEC announced its first FCPA enforcement action in 2022. South Korean telecommunications company, KT Corporation, agreed to pay $6.3 million to settle FCPA violations.  As part of the settlement, KT Corp. agreed to pay...more

Foley Hoag LLP - White Collar Law &...

Anti-Corruption in 2022: A Look Ahead

This is the second post in this year’s series examining important trends and new development in white collar law and investigations. Our previous post discussed health care enforcement. Up next: trends in tax enforcement. ...more

Goodwin

2021 Year in Review: FCPA

Goodwin on

A. Basic Overview of Statute - The Foreign Corrupt Practices Act of 1977, as amended, 15 U.S.C. §§ 78dd-1, et seq. (FCPA), makes it unlawful for U.S. persons and entities and others who act within the jurisdiction of the...more

Eversheds Sutherland (US) LLP

Enforcement appears as messages disappear: The perils of personal and ephemeral messaging

On December 17, 2021, a financial institution agreed to pay $200 million in fines to the Securities and Exchange Commission and Commodities Futures Trading Commission for allowing employees to discuss business on their...more

The Volkov Law Group

WPP SEC FCPA Enforcement Action: Lessons Learned (Part III of III)

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The SEC’s FCPA enforcement action against WPP presents a number of important lessons learned, ranging from third-party risk management, properly responding to employee complaints and red flags, and failure to integrate...more

The Volkov Law Group

WPP, the Largest Global Advertising Group, Settles FCPA Charges with SEC for $19.2 Million (Part I of III)

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After a long hiatus, the SEC announced a settlement with WPP plc, the world’s largest advertising group, for FCPA violations in India, China, Brazil and Peru for $19.2 million.  The SEC’s resolution charges WPP with...more

The Volkov Law Group

OCC Fines JP Morgan Chase $250 Million for Deficient Internal Controls

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Banking regulators have been flexing their muscles.  With the coming Biden Administration, this may portend the beginning of a new, enforcement wave.  Some have suggested that banks are resolving these cases before a more...more

The Volkov Law Group

DOJ Hits Beam Suntory with FCPA Settlement for $19.5 Million (Part I of II)

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Beam Suntory, a global producer and distributor of distilled beverages, settled its FCPA case with DOJ for $19.5 million for bribes paid in India.  The DOJ settlement follows an SEC FCPA settlement for $8 million announced...more

The Volkov Law Group

J&F Investmentos Subsidiary, Pilgrim’s Pride, Agrees to $110 its Million Penalty for Antitrust Cartel in Chicken Processing...

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Shortly before announcing its comprehensive FCPA settlement with DOJ and the SEC, Pilgrim’s Pride agreed with the Justice Department’s Antitrust Division to plead guilty to price-fixing in the chicken processing industry....more

The Volkov Law Group

SEC FCPA Settlement: J&F Investmentos Bribery Scheme (Part III of V)

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The SEC settled with J&F Investmentos (“J&F”) for approximately $27 million.  Unlike the DOJ settlement, the SEC included JBS and Joseley and Wesley Batista in its enforcement action.  The factual predicate for the settlement...more

Thomas Fox - Compliance Evangelist

HorrorFest 2020 Celebration: The Revenge of Frankenstein and the J&F FCPA Resolution

In this third edition of October HorrorFest 2020 celebration we consider the first Hammer film sequel (and second in the series) – The Revenge of Frankenstein which was released in 1958. It begins as the Curse of Frankenstein...more

Thomas Fox - Compliance Evangelist

Farewell to Tom Terrific and Using a Risk Assessment to Design Internal Controls

Today, I want to use the rigor in the preparation of Seaver to introduce the topic of how to use a risk assessment to provide a structured approach to establishing effective internal controls. ...more

The Volkov Law Group

World Acceptance Corporation Settles FCPA Charges with the SEC for $21.7 Million

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World Acceptance Corporation (“WAC”), a US-based consumer loan company, agreed to pay the SEC $21.7 million for FCPA violations in Mexico.  WAC’s cited violations covered the full gamut of FCPA violations, including bribery...more

The Volkov Law Group

Novartis and Alcon FCPA Enforcement Action: Lessons Learned (Part III of III)

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At the outset, Novartis is “lucky” – the settlement is relatively positive, despite its 2016 SEC enforcement action in China.  Given Novartis weak culture of compliance (if anything, a better description may be a culture of...more

Jones Day

DOJ Updates Its "Evaluation of Corporate Compliance Programs" Guidance

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The Situation: The Department of Justice ("DOJ") has updated its "Evaluation of Corporate Compliance Programs" guidance for prosecutors. The Result: The updates provide additional insights into the factors the DOJ is...more

Thomas Fox - Compliance Evangelist

Recidivist Eni: Corruption, Controls and Books and Records

Eni S.p.A (Eni) joined the two-time Foreign Corrupt Practices Act (FCPA) loser ranks last week when it agreed to a Cease and Desist Order (Order) with the Securities and Exchange Commission (SEC) for violations of the...more

Thomas Fox - Compliance Evangelist

Continuous Improvement in a Compliance Program

Today, I consider what techniques you, as Chief Compliance Officer (CCO), can use to create continuous improvement in your compliance program. ...more

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