Wait, that’s covered? Insurability of Fines and Penalties Flowing From a Cybersecurity Breach
FCPA Compliance and Ethics Report-Episode 31-the FCPA Year in Review, Corporate Enforcement Actions
FCPA Compliance and Ethics Report-Episode 30-Interview with the FCPA Professor-Part 2
Condo complaints not in writing?
Health Data on Leased Photocopier Costs Company $1.2m—What Others Can Learn
The Justice Department is encouraging companies to voluntarily disclose criminal violations — “Come in and confess” and DOJ offers promises of a declination. But even a declination comes with a requirement — the company has...more
Georgia Laboratory Owner Pleads Guilty to Felony Anti-Kickback Statute Violations - On February 28, the US Department of Justice (DOJ) announced the guilty plea of Andrew Maloney, who, along with his clinical laboratory...more
Global cartel fine totals rebounded somewhat in 2019, approaching historical norms following two years of sharply lower fine levels. The $6.1 billion total is the highest global fine level since 2016. Most of the increased...more
In its continuing aggressive FCPA criminal enforcement program, DOJ announced the indictment of two former Alstom executives and a former Marubeni executive with FCPA violations arising from a bribery scheme in Indonesia....more
On January 27, 2020, the Department of Justice (DOJ) announced a $145 million settlement with electronic health record (EHR) vendor Practice Fusion to resolve civil and criminal allegations that it violated the Anti-Kickback...more
Note to Government Personnel: Don’t Disclose SARs - This week, major developments unfolded in the cases against two former federal government employees for their respective roles in disclosing Suspicious Activity Reports...more
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
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
On October 8, 2019, the Department of Justice (“DOJ”) issued a memorandum (“Memorandum”) providing guidance on how the DOJ’s prosecutors will handle inability-to-pay claims from companies, intending to provide companies—and...more
France is off to a strong start enforcing Sapin II, its December 2016 anti-corruption legislation. Since the enactment of the statute, the lead French investigating and prosecuting agencies, the Parquet National Financier...more
Standard Chartered Bank certainly has its troubles. You know a company is in trouble, however, when it breathes a sigh of relief after paying nearly $1.1 billion in fines and penalties and compares itself to BNP Paribas, the...more
In the wake of this week’s revelations of years-long and significant alleged money laundering failures involving ING Bank and Danske Bank, European regulators have circulated a confidential “reflection paper” warning national...more
The IRS-Criminal Investigation Unit (IRS-CI) is the Criminal Law Enforcement Arm of the IRS. Its conviction rate of over 90% is one of the highest in federal law enforcement. Those convicted pay taxes, penalties and...more
On Wednesday, July 27, 2017, the U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN) announced a $110 million fine levied against BTC-e, a digital currency exchange, for BTC-e’s alleged refusal to abide by...more
When most people across the globe think of Rolls-Royce, one word comes to mind – excellence. Yet that image largely relates to Rolls-Royce Limited, the automobile manufacturer, which was founded in 1909. Just a few years...more
The consequences of breaching sanctions in the UK are due to increase in April. Prominent among the new measures is the power for the Office of Financial Sanctions Implementation (OFSI) to impose a monetary penalty and to do...more
The Federal Reserve announced on August 3, 2016, that it would fine Goldman Sachs $36.3 million in connection with a leak of confidential information from its New York branch. The leak was discovered and reported by Goldman...more