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As everyone knows, I tend to repeat myself -- DOJ does as well. Over the past year, DOJ has warned global companies -- over and over -- about the coming criminal enforcement storm against companies for sanctions and export control violations. Deputy Attorney General Monaco coined the phrase -- "the new FCPA,"
Podcasts
DOJ announced settlements with two U.K.-based reinsurance brokers, H.W. Wood Limited (“Wood”) and Tysers Insurance Brokers ("Tysers") for their participation in a bribery scheme involving Seguros Sucre S.A. ("Sucre") and Seguros Rocafuerte S.A. ("Rocafuerte"), two state-owned insurance companies
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The Justice Department's Corporate Enforcement Policies and Program applies to prosecutions outside of the FCPA context. The impact of DOJ's new approach, encouraging voluntary disclosures, applies to other federal criminal cases, such as healthcare fraud. In a recent action, DOJ declined to prosecute HealthSun Health Plans
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The Tysers and Wood FCPA settlements reflect something old and something new in the FCPA enforcement world. On the old side, at the core of the FCPA violations was the critical role played by the intermediary company. Unlike most third-party FCPA cases, where a third-party may be enlisted
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As I always say, the factual underpinnings of every FCPA enforcement action provides important insights into bribery schemes. At the core of every scheme is the misappropriation of money from the company coffers for improper uses. To the extent a company has weak financial controls and is at risk for
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Bobby Butler, a well-known and long-time compliance professional, joins Michael Volkov for a thought-provoking discussion on the rise of the compliance profession. Bobby has had a long and successful career in compliance. He provides important insights into the evolution of the compliance profession, strategies for building compliance
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The Justice Department has brought three corporate FCPA enforcement actions in 2023 (if you include the Ericsson DPA breach settlement). With its recent announcement of a declination under the Corporate Enforcement Policy, DOJ has declined two FCPA cases and one healthcare fraud case in 2023. DOJ publicizes the declination letters
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Companies have a vested interest in preserving internal communications for a variety of reasons — to hold actors accountable, and to protect the organization from potential private and government claims or investigations that may have serious direct or collateral consequences. Companies that want to use ephemeral messaging systems can do so
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The Justice Department has had a slow year in FCPA enforcement (another profound grasp of the obvious). The reasons for this may be a question of timing elements in the pipeline of cases. What is clear is that pushing through an enforcement action and settlement requires increased coordination with a
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From Compliance to Sustainability December 6, 2023 10 am EST/4 pm CET SIGN UP HERE Gan Integrity and Control Risks have announced an important upcoming webinar addressing the evolving third-party risk management context -- From Compliance to Sustainability. Third-party risk management has evolved at a rapid pace over
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LRN’s annual Program Effectiveness Report is chock full of important findings. Frankly, LRN’s PEI Report is a “board worthy” report (as Donna Boehme used to say — every board member should read it). Susan and Michael discuss several important findings in LRN's 2023 Report: High-performing ethics
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The Biden Administration issued a sweeping Executive Order directing a broad set of government actions addressing consumer harms, discrimination, privacy protections and other issues stemming from the widespread use of artificial intelligence. While the Executive Order sets forth a set of requirements to various federal agencies, the actions will establish