I’m old enough to remember when seat belts were optional. And I remember people up in arms when seatbelt laws first passed. But now, my young adult children and their friends simply get in the car and buckle up without...more
Worth the Wait? DOJ finally released its Fraud Statistics for FY 2021 and announced the “second largest amount recorded” since 1986: FCPA Settlement and judgment exceed $5.6 billion...more
2/11/2022
/ Corporate Misconduct ,
Corruption ,
Cybersecurity ,
Department of Justice (DOJ) ,
Enforcement Actions ,
False Claims Act (FCA) ,
Fraud ,
Healthcare Fraud ,
Qui Tam ,
Regulatory Violations ,
Whistleblowers ,
White Collar Crimes
As we look past the Herbalife FCPA settlement with DOJ and the SEC for $123 million to resolve FCPA bribery and books and records violations, we are reminded of the variety of foreign government touchpoints and FCPA risks....more
9/10/2020
/ Books & Records ,
Bribery ,
China ,
Compliance ,
Corruption ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Herbalife ,
Popular ,
Risk Mitigation ,
White Collar Crimes
On June 21, 2019, OFAC changed its requirements for reporting on blocked or rejected transactions under 31 C.F.R. §501.604. With little fanfare, the interim rule published in the Federal Register greatly expands the...more
On Friday May 3, 2019, I attended the Rocky Mountain Securities Conference in Denver and heard from a number of regulators and industry experts, including SEC Commissioner Hester Peirce. ...more