Corruption, Crime & Compliance

Featured Articles:

4 Feb, 2020

Airbus FCPA Settlement: Review of Airbus Bribery Scheme (Part II of IV)

Almost every FCPA enforcement action contains important lessons learned in unraveling a bribery scheme. Airbus has three broad divisions: (1) Commercial Division; (2) Defense & Space Division; and (3) Helicopters Division. The bribery scheme involved China, three Chinese government entities (GE-1, GE-2, and GE-3), and three consultants: Consultant 1, an agent who received payments from Airbus during 2013 to 2015 that were intended for bribes...

General

3 Feb, 2020

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

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 charges with the United States, France, and the United Kingdom for its role in a bribery scheme, and to resolve Airbus’ violation of the International Trade in Arms Regulations...

Podcasts

2 Feb, 2020

Episode 125 — Interview of Elizabeth Slim, Senior Consultant at the Volkov Law Group: AML and Financial Compliance Trends

Elizabeth Slim, Senior Consultant at the Volkov Law Group, discusses Anti-Money Laundering and Financial Compliance trends. Liz recently joined the Volkov Law Group and has extensive experience in the banking and financial compliance industry. She is major thought leader in anti-money laundering compliance and enforcement, and a leader at ACAMS. In this Episode, Michael Volkov discusses Liz’s career and her thoughts on AML and financial...

General

30 Jan, 2020

OFAC Issues First Two Enforcement Actions of 2020

OFAC had a big year in 2019 and 2020 looks like a continuation. In the last week, OFAC issued two enforcement actions — Eagle Shipping (here) and Park Strategies (here). Eagle Shipping Eagle Shipping, a Marshall Islands company, headquartered in Stamford, Connecticut, agreed to pay OFAC $1.125 million to settle liability for 36 violations of the Burmese Sanctions program. Specifically Eagle Shipping dealt with Myawaddy...

General

29 Jan, 2020

DOJ Announces Voluntary Disclosure Program for Criminal Export and Sanctions Violations

The Justice Department is often criticized for its lack of transparency. But when it comes to policy changes or initiatives, DOJ is more than transparent – DOJ always tells the public what it plans to do and then does it. When people act surprised about a policy initiative or a DOJ announcement or speech on a subject, they simply failed to read DOJ’s statements or...

General

28 Jan, 2020

OCC Settles Penalty Action with Former Wells Fargo CEO for $17.5 Million and Issues Penalty Notices Against Five Former Wells Fargo Officials

The Office of the Comptroller of Currency (OCC) announced a $17.5 million settlement with former Wells Fargo Bank CEO John Stumpf’s role in the sales practices misconduct scandal. In addition, the OCC announced settlements with two other Wells Fargo officials: (1) Hope Hardison, former Chief Administrative Officer and Director of Human Resources, Cease and Desist Order and $2.25 million civil money penalty; and (2) Michael...

General

27 Jan, 2020

Why a Duck — Episode 9, A Night at the Opera, Part 1 and 2019 Compliance Year in Review

In this episode, Tom Fox and Mike Volkov begin a three-part series where they discuss the classic movie A Night at the Opera and how it informs 2019 in compliance, FCPA enforcement actions and ethics/compliance trends. The Episode is available Here.

General

27 Jan, 2020

False Claims Act 2019 Year in Review

Jessica Sanderson, Of Counsel at The Volkov Law Group rejoins us for her annual review of False Claims Act enforcement. Jessica can be reached at [email protected]. 2020 marks the 150th anniversary of the Department of Justice (“DOJ”), and it unwrapped a nice gift: On January 9, 2020, DOJ released its Fraud Statistics showing that it obtained more than $3 billion under the False Claims Act...

Podcasts

26 Jan, 2020

Episode 124 — False Claims Act 2019 Review

The Justice Department continues to aggressively pursue False Claims Act cases. In 2019, DOJ recovered over $3 billion from healthcare, defense and financial companies. The heath care sector — pharmaceutical, medical device, hospitals and healthcare providers — continues to be the primary focus of False Claims Act cases. Qui tam relators initiate a significant percentage of all False Claims Act cases. In this episode, Michael Volkov...

General

23 Jan, 2020

Get Compliance Straight – The Need to Automate

I am reluctant to start off the New Year with a negative comment or posting. But I have a significant concern about the path and current state of ethics and compliance. From my vantage point, I have always been inspired by the forward momentum of the compliance profession. We have witnessed the unprecedented growth of the compliance profession – over the last twenty years, the...