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On July 2, 2020, DOJ and the SEC issued revised FCPA Guidance. The Revised Guidance continues to be a valuable document, which contains important discussions of relevant cases, DOJ and SEC policies, and enforcement principles relating to the FCPA. In this Episode, Tom Fox and Michael Volkov discuss the Revised
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Novartis is the new poster-child of corporate misconduct. In the space of two weeks, Novartis settled domestic False Claims Act and Anti-Kickback violations for $729 million, and settled FCPA violations for foreign bribery for $337 million. In the domestic False Claims Act and AKS cases, Novartis resolved two
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Notwithstanding the pandemic and remote working arrangements, the Securities and Exchange Commission is continuing to bring FCPA enforcement actions. In its latest action, the SEC settled with Alexion Pharmaceuticals for $21 million for foreign bribery and books and records violations. In this Episode, Michael Volkov reviews the Alexion FCPA enforcement
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Companies face a daunting challenge to reassure and regain trust and integrity with employees. CEOs should view the current situation as an opportunity to improve a company’s culture by building on the company’s trust and integrity values. Aside from basic economic questions, companies have to ensure that employee
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Even during this difficult time of the pandemic, economic uncertainty and social unrest, the Justice Department and the SEC have concluded a major FCPA enforcement action. Novartis and Alcon (which was a Novartis subsidiary at the time of the misconduct) agreed to pay a total of $345 million in criminal
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The Justice Department’s recent revisions to the Evaluation of Corporate Compliance Programs highlights an important trend and evolution of prosecution focus. DOJ’s Revised Corporate Compliance Guidance recognized and reinforced the continuing focus on post-acquisition integration versus pre-acquisition due diligence. For years, DOJ and compliance professionals placed
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The Justice Department’s Antitrust Division recently announced the indictment in Colorado federal court of four executives from two chicken producer companies for participation in a long-running price-fixing and bid-rigging conspiracy in the sale of broiler chickens to grocers, fast-food companies and other sellers of chicken
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The Department of Justice quietly issued revisions to its Corporate Compliance Program Guidance. DOJ's revisions underscore important new trends in corporate compliance -- the importance of resources and empowerment, continuous monitoring, proactive strategies, access to and use of data, consistent discipline and new, training strategies. In this episode, Michael
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Paul Kruse, former CEO of Blue Bell Ice Cream, was recently charged with criminal charges stemming from the sale of contaminated ice cream, resulting in the death of three persons. Kruse was aware of serious safety and contamination issues arising from the production of Blue Bell ice cream. Notwithstanding his
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Boeing Airlines was the leader in safety and financial success. Unfortunately, Boeing has suffered a significant fall from grace as a result of its 737 Max safety record and two devastating crashes in Indonesia and Ethiopia. The Boeing safety scandal has had a devastating impact on Boeing's performance
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The Covid-19 pandemic has had a devastating impact. Businesses have had to adjust rapidly to a new world, filled with significant healthy and safety risks, along with business survival and continuity issues. Companies have reacted with crisis management strategies. As part of this response, companies have to implement a
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In a two-part series, Michael Volkov examines the continuing problem of identifying and mitigating beneficial ownership risks. Money launderers and corrupt individuals continue to rely on corporate structures to disguise their ownership interests to further illicit schemes. Companies have to develop strategies that practically address the risks without dedicating