Episode 379 -- Update on False Claims Act and Customs Evasion Liability
2 Gurus Talk Compliance: Episode 55 – The From Worse to Worser Edition
Daily Compliance News: July 17, 2025, The COSO Yanked Edition
Podcast - Persistence and Determination
Episode 377 -- Refocusing Due Diligence on Cartels and TCOs
Blowing the Whistle: What Employers Should Know About DEI & the False Claims Act
Regulatory Ramblings: Episode 73 - Geopolitical Risk: Thai Tensions / Sanctions, Tariffs & FCPA Enforcement in Asia
When DEI Meets the FCA: What Employers Need to Know About the DOJ’s Civil Rights Fraud Initiative
Episode 376 -- DOJ's Unicat Settlement and the Future Look of Trade Enforcement Actions
False Claims Act Insights - Bitter Pills: DOJ Targets Pharmacies for FCA Enforcement
Current Regulatory, Legislative, and Litigation Developments on ADA Website Accessibility for Consumer Finance Digital Platforms — The Consumer Finance Podcast
Podcast - How Do You Define Success?
Episode 374 -- Justice Department Resumes FCPA Enforcement with New, Focused Guidance
10 For 10: Top Compliance Stories For the Week Ending June 21, 2025
2 Gurus Talk Compliance – Episode 54 – The FCPA is Back On Edition
Understanding the DOJ's Recent Corporate Enforcement Policy Changes
Compliance Tip of the Day – New FCPA Enforcement Memo – What Does it Mean?
Daily Compliance News: June 17, 2025, The JBS Goes Public Edition
False Claims Act Insights - Will Recent Leadership Changes Lead to FCA Enforcement Policy Changes?
On March 21, 2025, the Supreme Court continued its push back on an expansive reading of the federal criminal laws involving fraud and corruption by overturning the false statement conviction of Patrick Daley Thompson. In a...more
On March 7, Deputy Attorney General Lisa Monaco delivered the keynote remarks at the American Bar Association’s (ABA) 39th National Institute on White Collar Crime. She noted that artificial intelligence (AI) “holds great...more
Non-U.S. banks that maintain correspondent accounts in the United States face the prospect of significantly broader subpoenas from the Department of Justice (“DOJ”) and the Department of Treasury (“Treasury”) as a result of...more
The Justice Department and the Treasury Department’s Office of Foreign Asset Control (OFAC) are on a roll. Global banks are facing renewed prosecutions, along with aggressive sanctions prosecutions of companies for...more
David Crow, writing in a Financial Times (FT) article, entitled “Key questions for Goldman Sachs about Malaysian scandal”, said that Goldman Sachs was scheduled to meet with the Department of Justice (DOJ) this week. Crow...more
Big tech (including Facebook, Google [theoretically], and Twitter) is heading back to the Hill (with @jack pulling double-duty, because that’s how he rolls). Here’s what to expect today based on their prepared testimony....more
Last week Credit Suisse Group AG (CSAG) and Credit Suisse (Hong Kong) Limited (CSHK), a subsidiary of CSAFG, settled a Foreign Corrupt Practices Act (FCPA) enforcement action for just over $77 million for the illegal hiring...more
Credit Suisse has joined the ranks of other banks and companies that have settled FCPA violations involving hiring of government officials’ relatives in exchange for business benefits, including JPMorgan Chase; BNY Mellon,...more
Credit Suisse Group AG and its Hong Kong subsidiary settled FCPA charges with the Justice Department and the Securities and Exchange Commission. The Justice Department announced that Credit Suisse’s Hong Kong subsidiary...more
While I am not sure how much celebrating HSBC might be doing this week, they should have pride in making it through the five-year DPA. The bank worked very hard to overcome its miss-steps and hopefully it will continue to do...more
Yesterday I posted a book review of Jesse Eisinger’s book The Chickenshit Club. I also posted a podcast of an interview I did with Eisinger and Paul Pelletier, a partner at Pepper Hamilton, who was a source in the book. The...more
This post discusses individual liability in AML/BSA enforcement, which is an area of increasing attention. Indeed, according to public statements by the government, individual liability is the focus of enhanced scrutiny...more
Today we honor one of the most iconic moments of World War II (WWII) and one of the most famous photographs of all time, that of the Marines raising the US flag on Mount Suribachi on the island of Iwo Jima. Marine...more
There is no question that the Justice Department has raised compliance program expectations in a number of areas. Whatever you may think about the efficacy or fairness of the FCPA Pilot Program, the Justice Department has...more
One of the factors that the U.S. Department of Justice (DOJ) considers in deciding whether to bring charges against a corporation is the existence and effectiveness of the corporation’s pre-existing compliance program. On...more
Earlier this week, the Securities and Exchange Commission (SEC) announced resolution of a Foreign Corrupt Practices Act (FCPA) enforcement action involving the Hitachi Ltd (Hitachi). There were several interesting aspects to...more
As we come to the close of the Obama Administration, the Justice Department will certainly be able to point to its record of aggressive white-collar enforcement in a variety of areas. One glaring claim omission from that list...more