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Department of Justice (DOJ) Compliance Regulatory Violations

Thomas Fox - Compliance Evangelist

TD Bank: Part 4- Watergate, Actual Knowledge and Conscious Indifference

Mike Volkov often told the story of watching the Watergate Hearings as a teenager and being a seminal influence on his later professional life in the legal profession and government service. It was my first exposure to...more

Bass, Berry & Sims PLC

The United States Intervenes in its First False Claims Act Cybersecurity Case

Bass, Berry & Sims PLC on

The United States notified the U.S. District Court for the Northern District of Georgia that it plans to intervene in a False Claims Act case filed against Georgia Tech Research Corporation (Georgia Tech) by its Associate...more

The Volkov Law Group

Top Compliance Reminders from 2023 FCPA Enforcement

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While 2023 was a relatively slow year in FCPA enforcement, the DOJ and SEC settlements announced throughout the year set out a list of important ethics and compliance reminders. While these may seem obvious to everyone, I...more

The Volkov Law Group

2023 FCPA Year in Review — Questioning the Tea Leaves and Trends

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FCPA trends often are relatively easy to describe and often overblown as a marketing technique by the usual cast of paparazzi suspects.  (Self-proclaimed prognosticators that often push incorrect themes to promote business,...more

The Volkov Law Group

Justice Department Declines FCPA Prosecution Against Lifecore Biomedical Under Corporate Enforcement Policy

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The Justice Department has brought three corporate FCPA enforcement actions in 2023 (if you include the Ericsson DPA breach settlement).  With its recent announcement of a declination under the Corporate Enforcement Policy,...more

Thomas Fox - Compliance Evangelist

Albemarle FCPA Enforcement Action: Part 4 – Internal Control Failures

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

Thomas Fox - Compliance Evangelist

3M in China-Where Secret Travel = FCPA Violations

You know that when the Securities Exchange Commission (SEC) uses the word ‘secretly’ when discussing a corporate program, it is a seriously not good look. That is certainly the case in the recently announced Foreign Corrupt...more

The Volkov Law Group

3M Corp Pays SEC $6.5 Million to Resolve FCPA Charges

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The SEC is having a good year in prosecuting FCPA cases.  The SEC’s recent settlement with 3M Corp. for $6.5 million is its seventh corporate resolution for the year.  DOJ, which has been relatively quiet so far this year,...more

The Volkov Law Group

Corficocolombiana and Grupo Aval Pay $80 Million to Settle DOJ and SEC FCPA Violations in Colombia (Part I of II)

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The Department of Justice has been relatively quiet this year in bringing corporate FCPA enforcement actions and settlements.  Aside from the Ericsson breach of its Deferred Prosecution Agreement, the Corficocolombiana...more

The Volkov Law Group

2022: The FCPA Year in Review

The Volkov Law Group on

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

Gardner Law

Transatlantic Legal-Regulatory Update: Live from the Heart of Silicon Valley

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US and EU Life Sciences Law firms Fieldfisher & Gardner Law recently held a CLE event in Silicon Valley covering Healthcare Compliance, Data Privacy and Regulatory hot topics for MedTech and Pharma companies. Discussion...more

The Volkov Law Group

Lafarge and Syrian Subsidiary Pay $778 Million in Fines and Forfeiture for Supporting ISIS Terrorist Organization

The Volkov Law Group on

The Justice Department continues to push an aggressive agenda against businesses.  It is committed to demonstrating its resolve to prosecute companies and individuals from the business community.  Whether it is antitrust,...more

The Volkov Law Group

Sanctions Enforcement: “The New FCPA”

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Hold onto your hats – while we are on the cusp of more FCPA enforcement actions, the Justice Department and OFAC are gearing up for real and significant sanctions enforcement actions.  The dye is cast, so here we go. ...more

The Volkov Law Group

2020 Year in Review: Interesting Enforcement Actions (Part III of IV)

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DOJ and the SEC each had a great year in FCPA enforcement.  But it is important to acknowledge that the blockbuster case, Goldman Sachs, was the driver of this successful year. ...more

The Volkov Law Group

2020 FCPA Review: Another Record Year for Enforcement (Part I of IV)

The Volkov Law Group on

The Justice Department and the Securities and Exchange Commission had another record year of enforcement.  In fact, the last four years of FCPA enforcement included two years of record enforcement – 2019 and 2020.  After...more

The Volkov Law Group

Goldman Sachs and the Economic Impact of Corruption

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The breadth of Goldman Sachs’ corruption in the recent DOJ and SEC FCPA enforcement action underscored the important global goal of reducing corruption.  It goes without saying – corruption has a pernicious impact on economic...more

The Volkov Law Group

Daimler AG and Mercedes Benz Settle with US for $1.5 Billion for Emissions Cheating

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The Justice Department, the Environmental Protection Agency and the California Resources Board  announced a joint settlement totaling roughly $1.5 billion with Daimler AG and its US subsidiary Mercedes Benz to resolve...more

The Volkov Law Group

Ethics and Compliance Trends and Predictions for 2020

The Volkov Law Group on

2019 was a big year for ethics and compliance.  In fact, it is easy to argue that since the adoption of the compliance provisions in the US Sentencing Guidelines in 1991, compliance had its biggest year....more

Skadden, Arps, Slate, Meagher & Flom LLP

Ericsson Agrees To Pay Over USD $1 Billion To Settle FCPA Charges

On December 6, 2019, Telefonaktiebolaget LM Ericsson (Ericsson or the Company), resolved long-running investigations by the U.S. Department of Justice (DOJ) and the U.S. Securities and Exchange Commission (SEC) into the...more

Thomas Fox - Compliance Evangelist

Top Five Department of Justice FCPA Enforcement Actions in 2019

Welcome to the 2020’s. The past decade helped shape both Foreign Corrupt Practices Act (FCPA) enforcement and corporate compliance programs. 2019 FCPA enforcements bore out many of the developments from the preceding years of...more

Thomas Fox - Compliance Evangelist

Billion Dollar Baby: Ericsson FCPA Enforcement Action - Part 4: The Double Whammy in Penalties

Last week the Justice Department (DOJ) announced a resolution of the long standing Foreign Corrupt Practices Act (FCPA) enforcement action involving Telefonaktiebolaget LM Ericsson (Ericsson), a multinational networking and...more

The Volkov Law Group

DOJ Tweaks FCPA Corporate Enforcement Policy

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The Department of Justice recently announced updates to its Foreign Corrupt Practices Act Corporate Enforcement Policy. While the changes were relatively minor, the modifications underscored important principles surrounding...more

Thomas Fox - Compliance Evangelist

Lessons Learned from the Samsung FCPA Enforcement Action

Last week, another Foreign Corrupt Practices Act (FCPA) case was resolved. It involved Samsung Heavy Industries Company Limited (SHI), a South Korea-based engineering company that provides shipbuilding, offshore platform...more

The Volkov Law Group

Samsung Agrees to Pay $75 Million to Resolve FCPA Violations (Part I of II)

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Samsung Heavy Industries agreed with the Justice Department to pay $75 million to settle FCPA charges. Under a three-year deferred prosecution agreement (DPA), Samsung agreed to filing of a criminal information in the Eastern...more

The Volkov Law Group

DOJ Charges Two Herbalife Executives with Criminal FCPA Violations

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Last week, DOJ announced the indictment of two former Herbalife executives in China for participating in a bribery scheme over a ten-year period.  Herbalife, a multi-level marketing company, was not charged and its...more

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