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Jessica Sanderson, Partner at The Volkov Law Group, joins us for her annual False Claims Act Review. Jessica can be reached at jsanderson@volkovlaw.com. $1.9 trillion dollars of federal spending on the horizon. That’s right, immediately following his inauguration in 2021, President Biden proposed a $1.9
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President Biden has nominated Merrick Garland and Lisa Monaco to head the U.S Department of Justice. In addition, the Biden Administration has nominated a number of strong enforcement candidates to head up various regulatory agencies. The implications of this new team across the government will be significant on various
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In 2020, the Justice Department brought criminal charges against 22 individuals in FCPA-related investigations. While this was a decline from the two preceding years, COVID-19 had a dramatic impact on criminal FCPA prosecutions. In particular, DOJ faced challenges from unavailable grand juries to present evidence needed to bring
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In a harbinger of future enforcement actions surrounding AML compliance program violations, the Treasury Department’s The Financial Crimes Enforcement Network announced a $390 million settlement with Capital One for weaknesses in its AML program. Capital One was credited $100 million for its 2018 payment to the Office of the
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Deutsche Bank’s ethics and compliance function faces numerous challenges. Deutsche Bank has a storied record of scandals, government enforcement actions and failures to abide by prior deferred prosecution agreements (DPAs). When you review these matters, Deutsche Bank’s track record reflects serious culture and control deficiencies, including participation of
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Deutsche Bank, the infamous German bank connected to President Trump, settled FCPA and fraud cases with the Justice Department and the SEC, and agreed to pay a total of $130 million. The settlement included resolution of fraud charges against Deutsche Bank relating to a commodities fraud scheme, commonly referred to
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The Justice Department handed Walmart a huge slap in the face last year with the filing of a comprehensive civil case alleging that Walmart knowingly distributed large quantities of opioids in disregard of the law that fueled the national opioids crisis. In a lengthy complaint (160 pages), DOJ outlined Walmart’
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Congress enacted The Corporate Transparency Act, as part of the National Defense Authorization Act. The CTA expands beneficial ownership disclosure requirements for US entities. The new disclosure requirements target shell companies and small businesses to ensure disclosure beneficial ownership information. Liz Slim, Senior Counsel at The Volkov Law Group, interviews
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Sabre Corporation, the travel technology company, agreed to pay $2.4 million as a settlement with twenty-seven (27) State Attorneys General for a 2017 data breach involving hotel booking services. In 2017, Sabre suffered a major data breach involving 1.3 million credit cards. Sabre was cited for failing
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The 2020 OFAC enforcement record underscores the importance of sanctions compliance. Yet, companies appear to move slowly in response to sanctions risks, often relying on outdated or outmoded screening technologies and failing to build basic policy controls and procedures. In reviewing the 2020 enforcement actions, many of the cases involve
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The pandemic and its impact is the story of 2020 – no doubt. Federal prosecutors and regulatory enforcement agencies faced unprecedented challenges. In the face of these challenges, however, enforcement almost across the board continued with some significant exceptions relating to individual criminal enforcement. Prosecutors faced almost impossible obstacles to convening
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Whew! 2020 is over and we can start the New Year with hope – a fresh approach to restoring life “as it was before.” It is hard to imagine life before 2019 because no matter what – we have been changed forever. So, we need to let go of whatever notion we