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On December 5, 2024, DOJ announced a settlement with McKinsey and Company for $122 million for bribes paid to South African government officials to secure valuable consulting contracts. Between 2012 to 2016, McKinsey Africa, acting through former senior partner Vikas Sagar, who plead guilty in 2022, conspired to pay bribes
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The Department of Justice Antitrust Division's is playing catch up to the Criminal Division on compliance leadership. DOJ's Criminal Division has issued four separate revisions to its Evaluation of Corporate Compliance Programs. This is the Antitrust Division's first revision to its Evaluation of Corporate
Podcasts
What happens when a Chief Executive Officer becomes the architect of a global bribery scheme? In this episode of Corruption, Crime, and Compliance, Michael Volkov delivers an in-depth analysis of the BIT Mining FCPA case — a landmark matter that underscores the severe consequences of C-suite misconduct. With CEO
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Bit Mining, formerly 500.com, was a doomed company from the beginning, When a CEO orchestrates a bribery scheme with the assistance of other senior executives, shareholders and the public have little chance of ensuring a business operating with ethics and integrity. 500.com's future was sealed when
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In reviewing FCPA bribery fact patterns, it is a rare occasion when a company's CEO is at the epicenter of the criminal conspiracy. In the BIT Mining case, standing atop all of the actors is the CEO Zhengming Pan, Bit Mining's former CEO and a Chinese
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Earlier this year, Bit Mining and its CEO fell under the FCPA hammer. Bit Mining, formerly known as 500.com, resolved investigations with the Justice Department and the SEC for its corrupt scheme to bribe Japanese government officials. On the same date, DOJ announced the indictment of Zhengming Pan, Bit
Podcasts
Telefónica Venezolana C.A. ("Telefónica Venezolana"), the Venezuela-based subsidiary of Telefónica S.A. (Telefónica), the Spanish telecommunications company entered into a deferred prosecution agreement ("DPA") and agreed to pay over $85.2 million to resolve DOJ FCPA charges stemming from bribery payments to Venezuelan government
Events
2024 FCPA Year in Review January 7, 2024, 12 Noon EST SIGN UP HERE FCPA: For the Justice Department and the SEC, 2024 was an interesting year in FCPA enforcement and compliance. With the new Trump Administration taking over in 2025, DOJ's commitment to FCPA enforcement may be
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In one of the more notable enforcement actions of 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control ("OFAC") recently imposed a $1,104,408 civil penalty on a U.S. person for 75 separate violations of the Iranian Transactions and Sanctions Regulations
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By: Daniela Melendez, Associate at The Volkov Law Group, and Alex Cotoia, Regulatory Compliance Manager. Daniela can be reached at dmelendez@volkovlaw.com and Alex can be reached out at acotoia@volkovlaw.com. The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) recently settled with
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In an interesting political twist, the difference in approaches to antitrust enforcement between Democrat and Republican Administrations has been narrowing. It used to be that the difference in party control of the Antitrust Division and the Federal Trade Commission would have a significant impact on enforcement priorities. That gap is
Podcasts
LRN consistently provides high-quality reports and important insights on ethics and compliance trends. Each year, LRN's Program Effectiveness Report is anticipated as an important source of cutting-edge ethics and compliance initiatives. LRN's Code of Conduct Report includes a number of important benchmarks for companies