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Womble Bond Dickinson

Navigating the Labyrinth: Artificial Intelligence in the Battle Against Trade-Based Money Laundering

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In the rapidly evolving financial landscape, governments worldwide are intensifying their focus on compliance in Know Your Customer (KYC) and Anti-Money Laundering (AML) efforts for financial institutions. Trade-Based Money...more

American Conference Institute (ACI)

[Event] Summit on Anti-Corruption & Compliance Programs - March 22nd - 23rd, Mexico City, Mexico

Hosted by American Conference Institute, the Mexico Summit on Anti-Corruption & Compliance Programs returns for another exciting year with curated programming that shines a global spotlight on anti-corruption compliance...more

Thomas Fox - Compliance Evangelist

The Berko FCPA Resolution – Lessons on Corrupt Deal Making

This week, the Securities and Exchange Commission (SEC) obtained a Final Judgment against Asante Berko, former employee of a Goldman Sachs subsidiary, for, as noted in the SEC Press Release, his role in orchestrating a...more

The Volkov Law Group

World Acceptance Corporation Settles FCPA Charges with the SEC for $21.7 Million

The Volkov Law Group on

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

Thomas Fox - Compliance Evangelist

Novartis FCPA Enforcement Action: Fines, Penalties and the Cost of Recidivism

This week I am reviewing the Foreign Corrupt Practices Act (FCPA) enforcement action involving the Swiss pharmaceutical company Novartis AG, its Greek subsidiary Novartis Hellas S.A.C.I. (Novartis Greece) and Alcon Pte Ltd.,...more

The Volkov Law Group

Novartis and Alcon FCPA Enforcement Action: Lessons Learned (Part III of III)

The Volkov Law Group on

At the outset, Novartis is “lucky” – the settlement is relatively positive, despite its 2016 SEC enforcement action in China.  Given Novartis weak culture of compliance (if anything, a better description may be a culture of...more

Thomas Fox - Compliance Evangelist

Novartis FCPA Enforcement Action: Internal Controls

This week I am reviewing the Foreign Corrupt Practices Act (FCPA) enforcement action involving the Swiss pharmaceutical company Novartis AG, its Greek subsidiary Novartis Hellas S.A.C.I. (Novartis Greece) and Alcon Pte Ltd.,...more

Burr & Forman

Walmart FCPA Settlement Shines Light On Corporate Compliance Programs

Burr & Forman on

June 20, 2019 – Walmart (NYSE: WMT) and its subsidiary, WMT Brasilia, agreed to a combined criminal penalty and disgorgement of $282M, together with WMT’s criminal guilty plea and undertakings in an NPA, to reach a global...more

The Volkov Law Group

SEC Settles FCPA Charges Against Ex-Panasonic Avionics Officers

The Volkov Law Group on

On December 19, 2018, the SEC announced settlements with two former senior executives of Panasonic Avionics Corporation. In April 2018, Panasonic Avionics settled FCPA charges with the Justice Department and the SEC and...more

The Volkov Law Group

Goldman Sachs and the 1MDB Criminal Prosecutions

The Volkov Law Group on

The 1Malaysia Development Berhad scandal (“1MDB scandal”) has been making headlines for the past few years. The turning point for US prosecutors was the cooperation of Malaysian law enforcement and the corruption allegations...more

Holland & Knight LLP

Petrobras Agrees to Pay More Than $1.8 Billion for Facilitating FCPA Violations

Holland & Knight LLP on

• Four years ago, Brazilian authorities began Operation Car Wash, a wide-ranging and still ongoing corruption and money laundering investigation that has spanned 11 countries. • The fallout continues with a recent U.S....more

The Volkov Law Group

CEO Falls to SEC FCPA Settlement

The Volkov Law Group on

Companies have definitely matured in the development and implementation of their ethics and compliance programs. Whether the pace has been rapid enough or is too slow, that is a debatable issue. A good litmus test for a...more

The Volkov Law Group

Sanofi Coughs Up $25 Million to Settle SEC FCPA Charges

The Volkov Law Group on

Well, add another pharmaceutical company to the FCPA healthcare “sweep.” Frankly, the term “sweep” makes it sound like a coordinated enforcement effort – instead, it is more accurate to think of it as multiple prosecutions...more

Thomas Fox - Compliance Evangelist

Lessons in Failures of Internal Controls

Last week’s announcement by the Securities and Exchange Commission (SEC) of the resolution of its outstanding Foreign Corrupt Practices Act (FCPA) enforcement action with Halliburton Company continues to resonate and provide...more

Thomas Fox - Compliance Evangelist

Rolls-Royce Global Enforcement Action: Part I

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 Volkov Law Group

Mondelez FCPA Enforcement Action — An Abuse of Prosecutorial Discretion?

The Volkov Law Group on

The first FCPA enforcement action for 2017 landed with very little fanfare. The SEC reached a settlement with Mondelez International for $13 million. The facts surround the hiring of an agent in India and the failure of...more

A&O Shearman

Shearman & Sterling’s Recent Trends and Patterns in the Enforcement of the Foreign Corrupt Practices Act (FCPA)/FCPA Digest -...

A&O Shearman on

Shearman & Sterling’s bi-annual Trends & Patterns in FCPA Enforcement report provides insightful analysis of recent enforcement trends and patterns in the US, the UK and elsewhere, as well as helpful guidance on emerging best...more

The Volkov Law Group

FCPA Enforcement Ramping Up Against Private Equity and Hedge Funds (Part III)

The Volkov Law Group on

The Och-Ziff settlement has now set the stage for the Justice Department and the SEC to focus its enforcement eye on the private equity and hedge fund industry. The Och-Ziff action was initiated in response to the SEC’s...more

King & Spalding

Major FCPA Enforcement Action Against Nation’s Largest Publicly Traded Hedge Fund

King & Spalding on

In one of the largest FCPA settlements in history, hedge fund Och-Ziff Capital Management Group LLC (“Och-Ziff”) recently resolved a long-running government inquiry by agreeing to $413 million in financial penalties and a...more

The Volkov Law Group

DOJ and SEC Deliver Body Blow to Private Equity and Hedge Funds: Och-Ziff Settles FCPA Violations for $412 Million (Part I)

The Volkov Law Group on

The Justice Department and the Securities Exchange Commission delivered a powerful FCPA enforcement message to private equity and hedge funds. Och-Ziff settled with the DOJ and SEC for total penalties of $412 million....more

Orrick, Herrington & Sutcliffe LLP

This Cold Bud Is For You: SEC Sanctions Anheuser-Busch for “Chilling” Employee from Communicating with SEC

On September 28, 2016, the SEC announced that Anheuser-Busch agreed to pay $6 million to settle charges of Foreign Corrupt Practices Act and Dodd-Frank whistleblower violations. The SEC’s order stated that AB InBev violated...more

Thomas Fox - Compliance Evangelist

Anheuser-Busch InBev and Lessons in Joint Venture FCPA Compliance

Just in time for National Beveridge Day comes the Foreign Corrupt Practices Act (FCPA) enforcement action involving Anheuser-Busch InBev (ABI), where the company paid $6 million to settle charges that it violated the FCPA and...more

The Volkov Law Group

Five Key Takeaways from Key Energy’s SEC FCPA Settlement

The Volkov Law Group on

The SEC, last week, announced its $5 million settlement with Key Energy. As always, FCPA settlements contain important examples of enforcement priorities and policies. Key Energy’s recent settlement is an example of the...more

The Volkov Law Group

DOJ and SEC Collect $22 Million from LAN Airlines for Conduct in Resolving Labor Dispute

The Volkov Law Group on

Last week, the Justice Department and the SEC announced parallel FCPA settlements totaling $22 million in fines, penalties and disgorgement against LAN Airlines, a Chile-based airline, for conduct in resolving a labor dispute...more

Thomas Fox - Compliance Evangelist

Shareholders Will Get to Trial in Petrobras Corruption Scandal Action

Yesterday I wrote about what may well be the next great bribery and corruption scandal across the globe involving the Venezuelan state oil company Petroleos de Venezuela SA (PDVSA). However, the current largest corruption...more

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