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Corruption Criminal Prosecution Deferred Prosecution Agreements

The Volkov Law Group

Episode 305 -- Deep Dive into SAP FCPA Settlement

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SAP agreed to a three-year deferred prosecution agreement, in exchange for the payment of approximately $220 million in penalties for bribe payments made to South African and Indonesia government officials. DOJ’s resolution...more

Wilson Sonsini Goodrich & Rosati

What Companies Can Learn from the FirstEnergy/Ohio GOP “Dark Money” Scandal

In June, two prominent Ohioans were sentenced for their involvement in one of the largest political scandals in Ohio’s history. Former Speaker of the Ohio House of Representatives Larry Householder and former Chair of the...more

The Volkov Law Group

Lessons Learned from Ericsson’s DPA Breach: An Internal Investigation Nightmare (Part III of III)

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This is not your typical FCPA enforcement action Lessons Learned column.  Instead, Ericsson’s breach of its DPA presents a laundry list of internal investigation errors – as a practitioner in this area, this is the nightmare...more

The Volkov Law Group

Ericsson’s DPA Breach Conduct – Failures to Disclose and Report (Part II of III)

The Volkov Law Group on

Ericsson’s breach of its 2019 Deferred Prosecution Agreement reads like an internal investigation horror show.  It is every investigator’s nightmare scenario – failure to discover evidence that was available to inform and...more

The Volkov Law Group

Ericsson Settles Breach of 2019 FCPA Deferred Prosecution Agreement: Agrees to Plead Guilty, Pay $206 Million, and Extend...

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Ericsson, a multinational telecommunications company, based in Sweden, settled its breach of its 2019 Deferred Prosecution Agreement, agreed to enter a guilty plea and pay a $206 million penalty.  In 2019, Ericsson entered...more

Latham & Watkins LLP

France’s New Guidelines on Deferred Prosecution Agreement Offer Welcome Clarity

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The guidelines provide useful insights into the mechanism of settlement agreements in criminal cases, and supersede previous guidelines published on June 26, 2019. Article 22 of Law No. 2016-1691 of December 9, 2016...more

The Volkov Law Group

Here Comes DOJ – Corporate Crime Enforcement

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Lisa Monaco, the Deputy Attorney General (No. 2 in DOJ), delivered an important speech at the National Institute of White Collar Summit.  Lisa was part of the Enron Task Force years ago and has a strong professional...more

Hogan Lovells

DAG Monaco announces shift in DOJ enforcement policies - Prioritizing corporate misconduct and individual accountability

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On October 28, 2021, Deputy Attorney General (DAG) Lisa O. Monaco gave the keynote address at the ABA’s 36th National Institute on White Collar Crime and announced a series of changes in the Department of Justice’s (DOJ)...more

The Volkov Law Group

Credit Suisse Settles Multi-Jurisdiction Bribery and Fraud Case for $547 Million (Part I of II)

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Credit Suisse Group AG (“Credit Suisse”), a global financial institution, and its London-based European subsidiary, Credit Suisse Securities (Europe) Limited (“CSSEL”) resolved a wide-ranging bribery and fraud scheme...more

The Volkov Law Group

DOJ Ends Standoff & Agrees to DPA with Huawei CFO Wanzhou Meng

The Volkov Law Group on

The long political and prosecution standoff between the U.S. Government/Department of Justice and Huawei/China ended abruptly last week when Wanzhou Meng, CFO of Huawei Technologies Co., Ltd. appeared in federal district...more

The Volkov Law Group

Former Ericsson Employee Indicted for Role in Foreign Bribery Scheme

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In a surprising (but fully warranted) twist, the Justice Department returned an indictment against a former employee of Telefonaktiebolaget LM Ericsson (“Ericsson”), a global telecommunications company, for his role in paying...more

The Volkov Law Group

Avanos Medical Pays $22 Million to Settle Criminal Mislabeling Charges for Surgical Gowns

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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

The Volkov Law Group

DOJ and SEC Announce First Corporate FCPA Settlement for 2021: Amec Foster Wheeler, a Wood Group Subsidiary, Agrees to Pay over...

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The Justice Department and the Securities Exchange Commission are back in business.  The first corporate FCPA enforcement action in 2021 came after a six-month hiatus in 2021.  While many commentators sought to read the...more

The Volkov Law Group

Julius Baer Bank Resolves Money Laundering Charges in FIFA Scandal and Pays Nearly $80 Million

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The Justice Department continues to pile up victories out of the world soccer FIFA federation bribery scandal.  Julius Baer Group, the Swiss banker, agreed to a three-year, deferred prosecution agreement (DPA) and to pay...more

Thomas Fox - Compliance Evangelist

The Vitol Enforcement Action: Part 4 – Lessons Learned

Today, I conclude my four-part exploration of the Vitol Inc. (Vitol) Foreign Corrupt Practices Act (FCPA) enforcement action. Vitol agreed to pay a combined $135 million to resolve matters. Interestingly, also included in the...more

The Volkov Law Group

Vitol Pays $163.7 Million to Settle FCPA Case (Part I of III)

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The Justice Department continues to produce FCPA resolutions in a record year for enforcement.  The latest, and perhaps the beginning of several end-of-year and end of the Trump Administration resolutions, is DOJ’s settlement...more

The Volkov Law Group

Goldman Sachs Settles Massive 1MDB Bribery Case and Agrees to Pay Nearly $3 Billion (Part I of III)

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The Justice Department finally closed out its investigation of Goldman Sachs’ massive bribery scheme involving Malaysia’s 1MDB fund.  The case is now the largest in US FCPA history (based on its payment to DOJ and related US...more

Hogan Lovells

Not a silver bullet: public procurement lessons from the G4S DPA

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On 17 July 2020, a three-year Deferred Prosecution Agreement (DPA) between the Serious Fraud Office (SFO) and G4S Care & Justice Services (UK) Ltd (G4S) was approved. This DPA is the second arising from fraudulent conduct in...more

A&O Shearman

Airbus Agrees Record-Breaking €3.6 Billion Settlement to Avoid Prosecution

A&O Shearman on

On 31 January 2020, Airbus SE (Airbus) reached final agreements with the French Parquet National Financier (PNF), the U.K.’s Serious Fraud Office (SFO) and the U.S. Department of Justice (DoJ) in order to resolve...more

Thomas Fox - Compliance Evangelist

Airbus Settlement: Part 5 – The UK Judgment on the DPA

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

The Volkov Law Group

Airbus Systemic Bribery and Export Violations: Understanding How a Company’s Compliance Program and Culture Failed (Part IV of IV)

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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

Jones Day

FCPA 2019 Year in Review

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In the third year of the Trump Administration, the biggest Foreign Corrupt Practices Act ("FCPA") headlines were record corporate fines and penalties, and a banner year of individual FCPA enforcement highlighted by three DOJ...more

Thomas Fox - Compliance Evangelist

Airbus Settlement: Part 2 – The Paper Compliance Program

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

The Volkov Law Group

Airbus Agrees to Pay $4 Billion in Global Settlement of Foreign Bribery and ITAR Violations (Part I of IV)

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In a blockbuster case, the Justice Department announced a global settlement with Airbus SE, a manufacturer of civilian and military aircraft, under which Airbus agreed to pay over $4 billion (yes, with a “B”) to resolve...more

Thomas Fox - Compliance Evangelist

Airbus Settlement: Part 1 – Introduction

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

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