The 2nd Trump Administration will mean significant change in foreign policy, most especially the importance of ending the Russia-Ukraine war, increased focus on Iran and its proxies, and aggressive use of trade policies and...more
11/13/2024
/ China ,
Compliance ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Export Controls ,
Imports ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Supply Chain ,
Tariffs ,
Trade Relations ,
Trade Retaliation ,
Trump Administration ,
Ukraine ,
US Trade Policies
As the dust settles on the U.S. Election, companies are quickly analyzing the impact for businesses, federal civil and criminal enforcement priorities and the implications for ethics and compliance. When a new Administration...more
11/12/2024
/ Administrative Agencies ,
Compliance ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Ethics ,
Foreign Policy ,
Foreign Relations ,
Regulatory Agenda ,
Regulatory Oversight ,
Rulemaking Process ,
Tariffs ,
Trade Wars ,
Trump Administration
The SEC notched another FCPA settlement, continuing its steady pursuit and resolution of FCPA cases. In the meantime, the Justice Department has been silent in the FCPA enforcement arena.
In this episode of Corruption,...more
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...more
How does a respected financial institution turn into a criminal operation? In this episode of Corruption, Crime, and Compliance, host Michael Volkov dives into the record-breaking $3 billion settlement between TD Bank and the...more
The Justice Department’s global settlement included a significant False Claims Act resolution, resulting in a second deferred prosecution agreement (“DPA”) for a three-year term. A criminal information was filed in the...more
11/1/2024
/ Bribery ,
Compliance ,
Criminal Investigations ,
Defense Contracts ,
Defense Sector ,
Deferred Prosecution Agreements ,
Department of Defense (DOD) ,
Enforcement Actions ,
False Claims Act (FCA) ,
Federal Acquisition Regulations (FAR) ,
Federal Contractors ,
Fraud ,
Qui Tam ,
Raytheon ,
Whistleblowers
Raytheon’s comprehensive settlement included FCPA violations and failures to make required disclosures to the Defense Department concerning fees and commissions. This portion of the settlement was filed in the Eastern...more
11/1/2024
/ Bribery ,
Compliance ,
Criminal Prosecution ,
Defense Sector ,
Deferred Prosecution Agreements ,
Department of Defense (DOD) ,
Enforcement Actions ,
False Claims Act (FCA) ,
Federal Contractors ,
Foreign Corrupt Practices Act (FCPA) ,
Fraud ,
ITAR ,
Raytheon ,
Settlement ,
Statutory Violations
Raytheon’s criminal conduct cut across a variety of topics — it is difficult to imagine but Raytheon’s misconduct occurred in separate parts of the company, involving violations of different laws. Like most cases, I always...more
10/31/2024
/ Compliance ,
Corporate Culture ,
Corporate Misconduct ,
Corruption ,
Criminal Investigations ,
Defense Sector ,
Department of Defense (DOD) ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Federal Acquisition Regulations (FAR) ,
Federal Contractors ,
Fraud ,
Leadership ,
Pricing ,
Raytheon
Raytheon Company (Raytheon) — a subsidiary of defense contractor, RTX (formerly known as Raytheon Technologies Corporation) — agreed to pay over $950 million to resolve the Justice Department’s investigations into: (i) a...more
10/29/2024
/ Arms Export Control Act ,
Bribery ,
Compliance ,
Criminal Prosecution ,
Defense Sector ,
Department of Defense (DOD) ,
Department of Justice (DOJ) ,
Enforcement Actions ,
False Claims Act (FCA) ,
Federal Contractors ,
Foreign Corrupt Practices Act (FCPA) ,
Fraud ,
ITAR ,
Raytheon ,
Settlement ,
Statutory Violations
How can companies ensure that their compliance programs are robust enough to handle today’s complex ethical challenges?
In this episode, Michael Volkov dives into the critical components of conducting an internal compliance...more
Teva Pharmaceuticals USA Inc. (Teva USA) and Teva Neuroscience Inc. (“Teva”) agreed to pay $450 million to resolve two matters that allege Teva violated the Anti-Kickback Statute (AKS) and the False Claims Act (FCA). Teva is...more
10/23/2024
/ Anti-Kickback Statute ,
Civil Monetary Penalty ,
Co-payments ,
Drug Pricing ,
Enforcement Actions ,
False Claims Act (FCA) ,
Fraud and Abuse ,
Generic Drugs ,
Health Insurance ,
Healthcare ,
Healthcare Fraud ,
Kickbacks ,
Medicare ,
Pharmaceutical Industry ,
Price-Fixing ,
Teva Pharmaceuticals
The SEC notched another FCPA settlement, continuing its steady pursuit and resolution of FCPA cases. In the meantime, the Justice Department has been silent in the FCPA enforcement arena. In its latest settlement, Moog,...more
The Justice Department's Antitrust Division has been aggressively pursuing civil enforcement actions. While criminal enforcement of antitrust laws has been depressed, DOJ has found success in pursuing civil and merger...more
TD Banks’ complete compliance disaster was reflected in every aspect of TD Bank’s business and compliance operations. It is not surprising that TD Bank’s deficient BSA and AML compliance program was known by its Board of...more
10/18/2024
/ Anti-Money Laundering ,
BSA/AML ,
Compliance ,
Corruption ,
Criminal Prosecution ,
Enforcement Actions ,
Financial Crimes ,
Financial Institutions ,
FinCEN ,
Money Laundering ,
OCC ,
White Collar Crimes
TD Bank’s $3 billion settlement included coordinated regulatory settlements with the Federal Reserve Board (“Federal Reserve”), The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”), and the...more
10/17/2024
/ Anti-Money Laundering ,
Bank Secrecy Act ,
BSA/AML ,
Compliance ,
Criminal Prosecution ,
Enforcement Actions ,
Financial Institutions ,
Financial Services Industry ,
FinCEN ,
FRB ,
OCC ,
Settlement ,
Statutory Violations ,
White Collar Crimes
“By making its services convenient for criminals, TD Bank became one,” Attorney General Merrick B. Garland. TD Bank joins the list of dysfunctional companies — add them to Wells Fargo, Wirecard, Volkswagen, General Motors,...more
10/16/2024
/ BSA/AML ,
Compliance ,
Corporate Culture ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Financial Crimes ,
Financial Institutions ,
Financial Transactions ,
Guilty Pleas ,
Money Laundering
In yet another reminder of the scope of Justice Department enforcement powers, and an important demonstration of the risks of non-compliance, the Justice Department and relevant banking agencies announced a $3 billion...more
10/15/2024
/ Anti-Money Laundering ,
Bank Secrecy Act ,
BSA/AML ,
Compliance ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Financial Institutions ,
Financial Services Industry ,
FinCEN ,
FRB ,
Guilty Pleas ,
OCC ,
Popular ,
Statutory Violations ,
White Collar Crimes
How prepared is your company to handle the evolving risks of artificial intelligence and other emerging technologies in its compliance program?
In this episode of Corruption, Crime and Compliance, Michael Volkov delves into...more
The Justice Department’s Antitrust Division has been aggressively pursuing civil enforcement actions. While criminal enforcement of antitrust laws has been depressed, DOJ has found success in pursuing civil and merger...more
10/8/2024
/ Anti-Competitive ,
Antitrust Violations ,
Banks ,
Competition ,
Debit and Credit Card Transactions ,
Debit Cards ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Exclusionary Clauses ,
Fees ,
Merchants ,
Monopolization ,
Visa Inc
How prepared is your organization to handle the evolving landscape of sanctions compliance?
In this episode of Corruption, Crime and Compliance, Michael Volkov dives into critical sanctions compliance cases and their...more
The Justice Department announced yet another version of its Evaluation of Corporate Compliance Programs. As everyone knows, the Justice Department’s guidance carries talismanic significance — it is an important document that...more
10/4/2024
/ Anti-Corruption ,
Artificial Intelligence ,
Compliance ,
Compliance Management Systems ,
Corporate Governance ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Enterprise Risks ,
Innovative Technology ,
Machine Learning ,
Risk Management ,
White Collar Crimes
The Commerce Department’s Bureau of Industry and Security (“DOC-BIS”) is adopting procedures to generate voluntary self-disclosures for violations of export controls laws. Companies have to weigh carefully the risks when...more
The SEC's recent settlement with Deere & Company for $9.9 million for FCPA violations is another textbook example of bribery schemes, which revealed the absence of a culture of compliance, and the circumvention of basic...more
Foreign companies with U.S. operations are struggling to navigate the landscape of sanctions compliance. OFAC has expressed its concern that foreign companies need to deploy U.S. based expertise and resources to ensure...more
Global companies face significant risks in their supply chains of compliance with OFAC’s economic sanctions regime. OFAC has emphasized the importance of conducting supply chain risk assessments and audits....more
9/26/2024
/ Audits ,
Compliance ,
Cosmetics ,
Due Diligence ,
Enforcement Actions ,
Goods or Services ,
North Korea ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Sanction Violations ,
Suppliers ,
Supply Chain