Episode 315 - Boeing Pays $51 Million for ITAR Violations
In June 2025, two former executives were each sentenced to more than three years in prison for conspiracy and failure to report hazardous products to the U.S. Consumer Product Safety Commission ("CPSC"), marking the first...more
The lead generation industry is fascinating. If there is one over arching mantra it is this– monetize all data available. And sometimes that can get folks into BIG trouble, especially when lead buyers end up pitching...more
On May 8, the Superior Court of Arizona in Maricopa County ordered a health care company to pay more than $30 million in restitution to the Arizona Health Care Cost Containment System (AHCCCS) due to the company’s alleged...more
A new DOJ policy directs prosecutors to focus on crypto fraud and use of digital assets to facilitate other crimes. On April 7, 2025, Deputy Attorney General Todd Blanche issued a Memorandum titled, “Ending Regulation by...more
Defendants often face a tough choice — challenge the government’s evidence and if convicted, face significant jail time. On the flip side, defendants who plead guilty and cooperate can earn significant sentencing reductions,...more
Albemarle Corporation (Albemarle), recently agreed to pay more than $218 million to resolve investigations by the U.S. Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) into violations of the...more
The Justice Department and the Securities and Exchange Commission bounced back in 2022 to restore their records for aggressive FCPA enforcement. At the same time, DOJ announced significant new compliance program...more
The Justice Department’s Antitrust Division has had a rough year in the criminal arena. While the Antitrust Division has aggressively blocked several proposed mergers, it has lost several significant criminal cases. ...more
The largest criminal monitorship in U.S. history has ended. On March 22, 2022 a U.S. judge ruled that Chinese telecommunications giant ZTE Corporation had completed the terms of its five-year probation, which began in 2017...more
Lab Owner Indicted For $100 Million Health Care Fraud Scheme - On November 2, 2021, a federal grand jury in the Western District of Arkansas indicted Billy Joe Taylor of Arkansas for an alleged health care fraud scheme. ...more
Over 90 percent of federal defendants plead guilty, and 83 percent of those who go to trial are convicted on at least one count.1 In most indicted federal cases, the question is not how to persuade a jury at trial, but how to...more
In December, the U.S. Sentencing Commission issued a report on the influence of the U.S. sentencing guidelines on average sentences imposed. The commission found that the guidelines "generally continue to have a substantial...more
NatWest pleaded guilty on Thursday 7 October 2021 to criminal charges brought by the UK financial services regulator, the Financial Conduct Authority (the “FCA”). The FCA had charged NatWest with failing to properly monitor...more
The healthcare industry faces cascading risks – one risk flows to another with compounding financial results. Three generic drug companies just experienced this cascading liability. ...more
Avanos Medical, a global medical device company, agreed to pay $22 million to resolve criminal charges relating to its fraudulent misbranding of its MicroCool surgical gowns....more
Goldman Sachs now sits atop all charts with the largest US FCPA bribery penalty, totaling approximately $2.9 billion. The second largest is Ericsson’s 2019 FCPA settlement for $1 billion....more
The Justice Department continues to pursue criminal cases against Venezuelan officials at Petróleos de Venezuela S.A. (PDVSA) in an attempt to strangle President Nicolas Maduro. DOJ has been pursuing a three-pronged strategy...more
Over the past several blog posts, I have been exploring the Airbus SE (Airbus) international anti-corruption settlement in some depth. One of the questions I have had and hopefully raised for readers is not why the overall...more
Last week, Airbus SE (Airbus) settled a long-standing corruption scandal by agreeing to enforcement actions in three countries; France, the United Kingdom and the US. The matter involved a massive, worldwide, long running...more
When reviewing a major enforcement case, I always ask two basic questions: What was the role of Board and senior management in the failure, and how did they fail to exercise proper oversight and ensure compliance?...more
The Justice Department has brought only a few enforcement actions that focus on FCPA and export control violations. Last year, Quad Graphics earned a declination for FCPA and OFAC violations. In 2013, Weatherford settled...more
Almost every FCPA enforcement action contains important lessons learned in unraveling a bribery scheme. Airbus has three broad divisions: (1) Commercial Division; (2) Defense & Space Division; and (3) Helicopters...more