Episode 315 - Boeing Pays $51 Million for ITAR Violations
The California Energy Commission (“CEC”) and Stanley Black & Decker, Inc. (“Black & Decker”) entered into a May 21st Settlement Agreement and Release (“Agreement”) addressing alleged violations of the California Appliance...more
New York AG Letitia James entered into a settlement with Equinox Group, LLC (Equinox Group), which operates fitness services under Equinox, Equinox+, and SoulCycle, resolving allegations that its subscription and cancellation...more
On May 14, Colorado Attorney General (AG) Phil Weiser announced that the state reached a settlement with MC Global Holdings, LLC, its associated companies, and owners (collectively MC) to resolve allegations that MC’s...more
On June 14, 2024, U.S. Department of Commerce Assistant Secretary for Export Enforcement, Matthew Axelrod, officially issued an order activating the suspended portion of a civil penalty that was imposed on U.S-based freight...more
The Commerce Department has adjusted its export control enforcement program. The Bureau of Industry and Security (“BIS”) announced the new administrative policies and gave notice to the industry and public. BIS is now...more
Drazen v. GoDaddy.com, LLC, No. 21-10199 (11th Cir. July 27, 2022) Plaintiffs’ Claims and Allegations - Plaintiff’s claims, and those advanced in two separately filed class action lawsuits alleging violation of the...more
Last week the Federal Trade Commission announced a privacy and data security enforcement action against the online retail platform CafePress. The allegations in the FTC’s complaint read like a list of worst practices,...more
The Federal Government continues ramping up enforcement of data security requirements by deploying significant new enforcement theories and tools in support of cyber and data security controls required by federal law....more
Fannie Mae has reached a historic $53 million settlement with the National Fair Housing Alliance (“NFHA”) and local fair housing organizations throughout the U.S. to resolve racial discrimination claims concerning Fannie...more
On February 9, 2022, the United States Department of Justice (DOJ) announced a $3.8 million settlement with Catholic Medical Center (CMC) of Manchester, New Hampshire. This settlement resolves allegations that CMC violated...more
You know what the happiest animal on Earth is? It's a goldfish. Y'know why? It's got a 10-second memory. Be a goldfish. During the pandemic, we have had a lot of lows, as well as a few highs. And that’s just in pop...more
On August 9, 2021, the California Department of Financial Protection and Innovation (DFPI) announced that it had entered into a settlement agreement with a Tustin-based student loan debt relief company, resolving...more
In a harbinger of future enforcement actions surrounding AML compliance program violations, the Treasury Department’s The Financial Crimes Enforcement Network announced a $390 million settlement with Capital One for...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
We all know it when we see it – a recurring fact pattern in which a company enlists a corrupt third party intermediary for one purpose (and one purpose only) – to pay a bribe. Let me give you a few examples....more
Earlier this month, the California Insurance Commissioner announced that AbbVie had entered into a settlement agreement with the California Department of Insurance (CDOI) to resolve allegations that the pharmaceutical...more
World Acceptance Corporation (“WAC”), a US-based consumer loan company, agreed to pay the SEC $21.7 million for FCPA violations in Mexico. WAC’s cited violations covered the full gamut of FCPA violations, including bribery...more
Is federalism alive and well? Has the federal government decided to give up “piling on” and “overfiling” in environmental enforcement actions? It seems so. On July 27, 2020, in an effort to promote federalism, U.S. Department...more
The CFPB announced that it has entered into a settlement with Cottonwood Financial, Ltd., to resolve alleged violations by Cottonwood of the CFPA, FCRA, and TILA in the course of marketing, servicing, and collecting on...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