Podcasts
The Justice Department continues to produce FCPA resolutions in a record year for enforcement. The latest is DOJ’s settlement with Vitol, Inc. (Vitol), an energy trading company. DOJ agreed to a three-year deferred prosecution agreement (DPA) in exchange for a criminal penalty of $135 million. One-third of
Podcasts
Companies have to implement a sanctions compliance program (SCP). The Treasury Department Office of Foreign Asset Control’s sanctions guidance issued in May 2019 is an extraordinary document and includes numerous prescriptive requirements. Companies ignore the SCP Guidance at their peril. The Treasury Department’s Office of Foreign Asset Control
Podcasts
In a far-reaching action, the Health and Human Services – Office of Inspector General (HHS-OIG) issued a Special Fraud Alert underscoring the “inherent fraud and abuse risks” associated with company-sponsored speaker programs. In this Episode, Michael Volkov reviews the HHS-OIG Fraud Alert. The Episode is available Here.
General
Brian Whisler is a long-time white collar practitioner at Baker McKenzie. Brian joined me to discuss the new Biden Administration and the enforcement outlook from the Biden Department of Justice. Brian has a unique perspective since he served as part of the DOJ transition in 2001 for the incoming
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The Justice Department and regulatory agencies have emphasized the importance of corporate culture and ethics. As companies approach this important issue, it is important to examine a variety of strategies to ensure that a corporate culture adheres to ethical standards. Jeffrey Tilton, CFE, a leader in the compliance field, has
Podcasts
Beam Suntory, a global producer and distributor of distilled beverages, settled its FCPA case with DOJ for $19.5 million for bribes paid in India. The DOJ settlement follows an SEC FCPA settlement for $8 million announced on July 2, 2018. The timing of the FCPA settlements is unusual and
Podcasts
The Department of Justice and eleven state Attorneys General filed an antitrust case against Google in the United States Court for the District of Columbia. DOJ’s filing was hurried at the behest of the Attorney General Bill Barr, and reflects DOJ’s growing focus on high-tech businesses and
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Medical device maker Merit Medical Systems (“MMS”) agreed to pay $18 million to resolve allegations that the company submitted false claims to Medicare, Medicaid and TRICARE by paying kickbacks to physicians and hospitals to induce increased use of MMS products. Dr. Charles J. Wolf, Merit's former chief compliance
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J&F Investimentos SA (“J&F), a Brazilian private investment company, plead guilty to FCPA bribery violations in federal court in Brooklyn, New York. As part of the plea agreement, J&F agreed to pay a fine of $256 million and to cooperate with ongoing investigations of
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The Justice Department finally closed out its investigation of Goldman Sachs’ massive bribery scheme involving Malaysia’s 1MDB fund. The case is now the largest in US FCPA history (based on its payment to DOJ and related US agencies). Goldman Sachs entered into three-year deferred prosecution agreement (“DPA”) with
Podcasts
Boeing is the new poster child for corporate governance failures and misconduct. Move over Wells Fargo, General Motors, Volkswagen, Novartis, Siemens and Wal-Mart, and make room for Boeing. Like General Motors and its ignition switch scandal, innocent consumers were killed as a direct result of corporate governance failures and
Podcasts
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