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On May 1, 2020, Blue Bell pleaded guilty to shipping contaminated ice cream linked to a 2015 listeria outbreak and agreed to pay a fine of $19.5 million ($17.4 million criminal fine and $2.1 million to settle civil false claims act violations). Blue Bell’s former CEO,
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Bausch Health agreed to pay the SEC $45 million to settle Valeant Pharmaceuticals (former name) accounting fraud schemes. Three former executives, former CEO Michael Pearson, CFO Howard Schiller and Controller Tanya Carro also settled with SEC. Pearson agreed to pay a civil penalty of $250,000 and repaid Bausch $450,
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It is hard to argue that Apple and Amazon do not have the resources to implement state-of-the-art OFAC compliance programs. After all, the two largest companies in the world should stand as beacons of compliance with the full support of senior management, robust compliance departments, and sophisticated
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In the last two years, OFAC has brought four enforcement actions that focus on an organization’s “screening errors.” These include: American Express; (2) Cobham Metalics; (3) Apple; and (4) Amazon. In today's posting, I will review American Express and Cobham Metalics. American Express On April 30, 2020,
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Here is another profound grasp of the obvious (for which I have a knack for delivering) – compliance and legal professionals can learn a number of lessons from individual enforcement actions. In many cases, however, there is much more to the story than the headline or the list of so-called
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When you are hot, you are hot. (And when you are not, you are not; Thank you Jerry Reed, Country Singer). OFAC is hot and resumed its enforcement streak, settling three enforcement actions in three weeks. The latest settlement involved Whitford Worldwide Company (Whitford”), a cookware manufacturer based in Pennsylvania,
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Steele Compliance Solutions announced the global rollout of its new “Risk Intelligence Data” platform. Companies are suffering from information overload -- with new technologies, companies can manage information to increase efficiency and accuracy in collecting and analyzing information needed for risk management purposes. Risk Intelligence Data involves the hybridization of over
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The Justice Department’s enforcement programs are resuming – False Claims Act, FCPA and other programs will continue. The rate of enforcement, however, is subject to change once again from the impact of the pandemic. As the pandemic continues to spread, DOJ focus on pandemic related fraud and other scams will
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DOJ’s aggressive enforcement of the opioid industry is a striking example of the power of federal prosecutors when focused on an industry. Once prioritized for enforcement, DOJ has quickly brought together prosecutors and law enforcement to target corporate actors and companies with the full force of criminal and civil
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The DOJ Antitrust Division’s multi-year criminal cartel investigation of the generic pharmaceutical industry is gaining steam. The latest company to settle is Taro Pharmaceuticals which agreed to enter a deferred prosecution agreement and pay a $205.7 million penalty to resolve charges relating to a criminal price-fixing
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The Justice Department and OFAC announced a settlement with Essentra FZE Company Limited (“Essentra FZE”), a cigarette filter and tear tape manufacturer, for violation of the North Korea Sanctions Program. The violations were based on payments for goods that were received by a foreign branch of a U.S. bank.
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Amazon joins the exclusive club of high-tech OFAC violators. Last year, Apple settled with OFAC for sanctions violations. This year, we can add Amazon to the list of OFAC violators. On July 8, 2020, Amazon settled with OFAC for $134,523 for violations of multiple OFAC sanctions programs. Amazon’