Wicked Coin: The "Fat Leonard" Scandal
Corruption, Crime & Compliance: Deep Dive into The Gunvor FCPA Settlement
Episode 307 -- Sanctions Enforcement Review and Predictions for 2024
Episode 300 -- Deep Dive into DOJ FCPA Settlement with Two U.K. Reinsurance Companies for Bribery in Ecuador
Episode 296 -- Deep Dive into Clear Channels SEC Settlement of FCPA Violations
Episode 294 -- Catch Up on OFAC Enforcement: 3M and Emigrant Bank
The Maritime Anti-Corruption Network: An In-Depth Conversation
Season 2 - Episode 2 - A Whistleblowers Nightmare: The Uncovering of the 1Malaysia Development Berhad Scandal
The Justice Insiders Podcast: Varsity Blues Reversals Turn DOJ Red
Corruption, Crime, and Compliance - The Ericsson FCPA DPA Breach Settlement
Episode 258 -- Deep Dive into ABB FCPA Settlement
Corruption Crime & Compliance - Deep Dive into the ABB FCPA Case
Life with GDPR - The ABB Enforcement Action from a UK Perspective
The Corruption Files - Episode 15 - The ABB Settlement
The Line Between Gift Giving and Bribery
The Corruption Files - Episode 14 - Walmart with Tom Fox and Michael DeBernardis
Compliance Into The Weeds - Lafarge and the Cost of Moral Bankruptcy
The New Cold War: Risk, Sanctions, Compliance Episode 21: "Interview with Drago Kos of the OECD Working Group on Bribery"
The Justice Insiders: FIFA Corruption Trial – Will the Feds Score Another Goal?
The Presumption of Innocence Podcast: Episode 5 - Doing Business Overseas: The Foreign Corrupt Practices Act
Five years since the Republic of Mozambique issued its claim in the English High Court against Privinvest and other participants in one of the largest sovereign corruption scandals of modern memory – the so-called "Tuna Bond"...more
The Department of Justice’s blockbuster FCPA settlement with Gunvor restores the credibility of DOJ’s pronouncements of DOJ’s commitment to aggressive FCPA enforcement. While I have questioned DOJ’s commitment to its...more
On March 7th, the Department of Justice (DOJ) announced a new whistleblower reward program intended to help prosecutors bring more foreign corruption cases. Under the new program, individuals who report corporate misconduct...more
This week, SAP SE (SAP), the German-based software company, agreed to pay over $200 million to resolve investigations by the US Department of Justice (DOJ) and US Securities and Exchange Commission (SEC) into violations of...more
The Justice Department’s FCPA enforcement record for 2024 was slow. This trend was unexpected, contrary to my own predictions and of various other prognosticators. It is hard to explain why this slowdown occurred....more
The Tysers and Wood FCPA settlements reflect something old and something new in the FCPA enforcement world. On the old side, at the core of the FCPA violations was the critical role played by the intermediary company....more
DOJ announced two recent FCPA settlements with U.K. based reinsurance brokers involving a long-running bribery scheme involving two Ecuadoran state-owned insurance companies. While DOJ has had a slow year in FCPA...more
The following is a summary of selected federal Department of Health and Human Services’ Office of Inspector General (OIG) reports of fraud and abuse enforcement activity across the country. The enforcement actions reported...more
On September 29, 2023, Albemarle Corporation (“Albemarle”), a global chemical manufacturer, reached an agreement with the U.S. Department of Justice (“DOJ”) and the Securities and Exchange Commission (“SEC”) to resolve...more
Last week, Albemarle Corporation (Albemarle), a publicly traded specialty chemicals manufacturing company headquartered in North Carolina, agreed to pay more than $218 million to resolve investigations by the U.S. Department...more
Albemarle Corporation (Albemarle), a specialty chemicals manufacturing company located in Charlotte, North Carolina, agreed to pay more than $218 million to settle FCPA investigations with DOJ and the SEC stemming from...more
You can always learn a lot from reviewing the underlying conduct to an FCPA enforcement action. Chief compliance officers can identify specific risk factors, mitigation steps and root causes for bribery schemes. ...more
Koninklijke Philips N.V., a global medical technology manufacturer, recently agreed to pay over $62 million to resolve a Foreign Corrupt Practices Act (FCPA) enforcement action with the Securities and Exchange Commission...more
In May 2023, a complex SEC law enforcement proceeding was concluded against Philips, a public Dutch medtech company. The proceeding concluded with a settlement, whereby Philips agreed to pay a fine of more than USD 62 million...more
Pennsylvania Medical Supply Company Agrees to $5 Million Settlement - A Pennsylvania medical supply company, AdaptHealth LLC, formerly known as QMES LLC, agreed to a $5.3 million settlement to resolve allegations that it...more
On December 30, 2022, FERC issued an order approving a stipulation between the Office of Enforcement and FirstEnergy Corp., which required FirstEnergy to pay a civil penalty and submit to compliance monitoring because...more
Oracle’s SEC settlement for $23 million underscores the power of the FCPA provisions mandating effective internal controls and accurate books and records. As everyone knows, these provisions can be applied to a wide-range of...more
On July 11, 2022, the United States District Court for the District of Kansas approved a $264 million settlement against Mylan and certain of its subsidiaries in the case In Re EpiPen (Epinephrine Injection, USP) Marketing,...more
On August 2, 2021, the Department of Justice (DOJ) announced that Arriva Medical LLC (Arriva), once the nation’s largest Medicare mail-order diabetic testing supplier, and its parent company, Alere Inc., have agreed to...more
We all know and hear about third-party risks – over and over again. Despite this recurring theme, organizations continue to pay the price for failing to address third-party issues. It does not take a rocket scientist to...more
FCPA settlement actions often underscore specific compliance risks for legal and compliance professionals. If there ever was a case where third-party risks were bungled, and even intentionally embraced, the Foster Wheeler...more
DOJ’s 2020 False Claims Act Recoveries Lowest Since 2008 - On January 14, 2021, the Department of Justice (DOJ) announced that it obtained more than $2.2 billion in settlements and judgments from civil cases involving...more
In the enforcement and compliance arena, there are instances of misconduct that underscore important governance principles. But this just sounds like a bunch of mumbo jumbo (the technical term, I know)....more
Report on Supply Chain Compliance 3, no. 21 (October 29, 2020) - Goldman Sachs has agreed to pay a penalty of USD 2.2 billion for its role in the robbing of 1Malaysia Development Berhad (1MDB), a Malaysian development...more
DOJ Announces Charges Against 345 Defendants in Historic Nationwide Health Care Fraud and Opioid Takedown - The DOJ announced a nationwide enforcement action charging 345 defendants across 51 federal districts with...more