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Corruption, Crime & Compliance offers both blog postings and fresh podcasts on important legal and compliance topics. To make your life a little easier, we offer a subscription service so that you receive convenient notices of new blog postings and podcast episodes. Here are the subscription links: Apple Podcasts | Android
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The Justice Department’s Antitrust Division’s criminal enforcement program is having a strong year. Since completing its long-term and record-setting prosecution of Japanese auto parts suppliers, the Antitrust Division focused attention on new industries, including generic pharmaceuticals, chicken processors, government contractors, electronic capacitors, and health care. It
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We all know it when we see it – a recurring fact pattern in which a company enlists a corrupt third party intermediary for one purpose (and one purpose only) – to pay a bribe. Let me give you a few examples. Cognizant Technology In the Cognizant Technology FCPA enforcement action, the
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The Justice Department announced a major expansion of its ongoing investigation and prosecution of executives and employees in the boiler chicken price-fixing conspiracy. DOJ recently returned a superseding indictment adding six new defendants to the boiler chicken conspiracy indictment, and expanding the scope of the charged conspiracy. (Here for
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The former deputy finance chair of the Republican National Committee and prominent fundraiser for President Trump has agreed to plead guilty with lobbying on behalf of Jho Low, an indicted and fugitive financier, who was charged in the ongoing 1MDB sovereign wealth fund investigation and prosecution. Broidy agreed to assist
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OFAC has resumed its aggressive enforcement program. These enforcement actions include: (1) Keysight Technologies settled with OFAC for $473,157 for violations of the Iran Sanctions Program; (2) Comtech Telecommunications settled with OFAC for $894,111 for violations of Sudan Sanctions Program; and (3) Deutsche Bank settles two OFAC cases
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By any measure, the SEC’s whistleblower program has been a success. Since its inception about 10 years ago, the SEC has collected $2.5 billion in financial recoveries based on whistleblower tips. A large portion of this money has been returned to victim investors. Section 922 of the Dodd-
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OFAC continues to chalk up enforcement actions. For the year, even with the pandemic slow down, OFAC has reached 13 settlement agreements totaling $18.6 million in penalties. In its latest enforcement settlement, Generali Global Assistance, Inc. (“GGA”), a US-based travel assistance services company that provides travel and claims
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JP Morgan Chase (“JP Morgan”) is not having a positive year when it comes to government enforcement. JP Morgan is at the brink of a multi-billion dollar FCPA settlement for its involvement in the 1MDB corruption scandal in Malaysia. Add to this a few regulatory enforcement actions: an SEC
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If you speak to members of a corporate board and the C-Suite and you ask them if the company has a strong ethical culture, we all know what they will say – “Of course, we do. We have a strong commitment to our Code of Conduct and Doing the Right
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In two recent FCPA enforcement actions, the Justice Department focused on bribery schemes involving Petroecuador government officials. Petroecuador is the state-owned oil and gas company in Ecuador. In the first, DOJ announced an indictment against Javier Aguilar, an oil trader at Vitol, an energy and commodity trading company, for