Corruption, Crime & Compliance

Featured Articles:

General

20 Dec, 2024

DOJ Indicts Indian Billionaire and Seven Other Individuals for Bribery and Fraud Scheme Involving Payments to Indian Government Officials to Obtain Solar Energy Contracts

In a far-reaching criminal case, in November 2024, the Justice Department unsealed a complex, five-count indictment in the Eastern District of New York charging eight defendants, including Gautam S. Adani, Sagar R. Adani and Vneet S. Jaain, executives of the Adani Group, a large Indian renewable-energy company, with conspiracies to commit securities and wire fraud and substantive securities fraud for their roles in a multi-billion-dollar...
General

19 Dec, 2024

Lessons Learned from McKinsey’s FCPA Enforcement Action — Local Partners and Third Parties (Part III of III)

Deja Vu all over again — Yogi Berra Yogi Berra said it best — we have seen this scenario before, with similar parties — corrupt foreign officials from Eskom (and Transnet), local partner requirements resulting in engagement of unqualified businesses, and corrupt third parties who assist the bribery scheme in exchange for a cut of the action. This is a familiar set of facts, and...
General

18 Dec, 2024

McKinsey Company’s Bribery Scheme — A Familiar Pattern in South Africa (Part II of III)

The McKinsey FCPA case follows several other significant cases involving South Africa. ABB and SAP resolved FCPA cases involving bribes in South Africa; on the SEC front, Gartner resolved a bribery case involving South Africa. Like these other cases, McKinsey’s bribery scheme focused on two important state-owned enterprises: Transnet Ltd, the South African company responsible for operation of ports, rails and pipelines; and Eskom Ltd.,...
General

17 Dec, 2024

McKinsey Company Pays $122 Million to Resolve FCPA Violations in South Africa (Part I of III)

On December 5, 2024, DOJ announced a settlement with McKinsey and Company for $122 million for bribes paid to South African government officials to secure valuable consulting contracts. Between 2012 to 2016, McKinsey Africa, acting through former senior partner Vikas Sagar, who plead guilty in 2022, conspired to pay bribes to high-ranking officials at two South African state-owned enterprises: Transnet SOC Ltd., which was the...
General

16 Dec, 2024

Antitrust Division Revises Evaluation of Corporate Compliance Programs in Criminal Antitrust Investigations

The Department of Justice Antitrust Division’s is playing catch up to the Criminal Division on compliance leadership. DOJ’s Criminal Division has issued four separate revisions to its Evaluation of Corporate Compliance Programs. This is the Antitrust Division’s first revision to its Evaluation of Corporate Compliance Programs. The Antitrust Division’s revisions mirror many of the Criminal Division’s recent revisions with a particular focus on emerging technologies,...

20 Dec, 2024

DOJ Indicts Indian Billionaire and Seven Other Individuals for Bribery and Fraud Scheme Involving Payments to Indian Government Officials to Obtain Solar Energy Contracts

In a far-reaching criminal case, in November 2024, the Justice Department unsealed a complex, five-count indictment in the Eastern District of New York charging eight defendants, including Gautam S. Adani, Sagar R. Adani and Vneet S. Jaain, executives of the Adani Group, a large Indian renewable-energy company, with conspiracies to commit securities and wire fraud and substantive securities fraud for their roles in a multi-billion-dollar...

General

19 Dec, 2024

Lessons Learned from McKinsey’s FCPA Enforcement Action — Local Partners and Third Parties (Part III of III)

Deja Vu all over again — Yogi Berra Yogi Berra said it best — we have seen this scenario before, with similar parties — corrupt foreign officials from Eskom (and Transnet), local partner requirements resulting in engagement of unqualified businesses, and corrupt third parties who assist the bribery scheme in exchange for a cut of the action. This is a familiar set of facts, and...

General

18 Dec, 2024

McKinsey Company’s Bribery Scheme — A Familiar Pattern in South Africa (Part II of III)

The McKinsey FCPA case follows several other significant cases involving South Africa. ABB and SAP resolved FCPA cases involving bribes in South Africa; on the SEC front, Gartner resolved a bribery case involving South Africa. Like these other cases, McKinsey’s bribery scheme focused on two important state-owned enterprises: Transnet Ltd, the South African company responsible for operation of ports, rails and pipelines; and Eskom Ltd.,...

General

17 Dec, 2024

McKinsey Company Pays $122 Million to Resolve FCPA Violations in South Africa (Part I of III)

On December 5, 2024, DOJ announced a settlement with McKinsey and Company for $122 million for bribes paid to South African government officials to secure valuable consulting contracts. Between 2012 to 2016, McKinsey Africa, acting through former senior partner Vikas Sagar, who plead guilty in 2022, conspired to pay bribes to high-ranking officials at two South African state-owned enterprises: Transnet SOC Ltd., which was the...

General

16 Dec, 2024

Antitrust Division Revises Evaluation of Corporate Compliance Programs in Criminal Antitrust Investigations

The Department of Justice Antitrust Division’s is playing catch up to the Criminal Division on compliance leadership. DOJ’s Criminal Division has issued four separate revisions to its Evaluation of Corporate Compliance Programs. This is the Antitrust Division’s first revision to its Evaluation of Corporate Compliance Programs. The Antitrust Division’s revisions mirror many of the Criminal Division’s recent revisions with a particular focus on emerging technologies,...

Podcasts

15 Dec, 2024

Episode 349 — The BIT Mining FCPA Settlement

What happens when a Chief Executive Officer becomes the architect of a global bribery scheme? In this episode of Corruption, Crime, and Compliance, Michael Volkov delivers an in-depth analysis of the BIT Mining FCPA case — a landmark matter that underscores the severe consequences of C-suite misconduct. With CEO Zhengmin Pan at the center of the conspiracy, BIT Mining’s efforts to infiltrate Japan’s emerging casino...

General

12 Dec, 2024

BIT Mining FCPA Settlement and Lessons Learned (Part III of III)

Bit Mining, formerly 500.com, was a doomed company from the beginning, When a CEO orchestrates a bribery scheme with the assistance of other senior executives, shareholders and the public have little chance of ensuring a business operating with ethics and integrity. 500.com’s future was sealed when it embraced bribery as a means to avoid head-to-head competition against established US and European companies seeking to enter...

General

11 Dec, 2024

BIT Mining Bribery Scheme — CEO Directed Payments and the Cover-Up (Part II of III)

In reviewing FCPA bribery fact patterns, it is a rare occasion when a company’s CEO is at the epicenter of the criminal conspiracy. In the BIT Mining case, standing atop all of the actors is the CEO Zhengming Pan, Bit Mining’s former CEO and a Chinese national. DOJ had no choice but to charge Pan with a criminal FCPA conspiracy. Others could have been charged...

General

10 Dec, 2024

BIT Mining CEO Indicted for FCPA Violations — Bit Mining Pays $10 Million to Settle DOJ and SEC FCPA Cases (Part I of III)

Earlier this year, Bit Mining and its CEO fell under the FCPA hammer. Bit Mining, formerly known as 500.com, resolved investigations with the Justice Department and the SEC for its corrupt scheme to bribe Japanese government officials. On the same date, DOJ announced the indictment of Zhengming Pan, Bit Mining’s former CEO and a Chinese national, for FCPA violations. BIT Mining entered into a three-year...

Podcasts

8 Dec, 2024

Episode 348 — Deep Dive into Telefónica DOJ Settlement for FCPA Violations

Telefónica Venezolana C.A. (“Telefónica Venezolana”), the Venezuela-based subsidiary of Telefónica S.A. (Telefónica), the Spanish telecommunications company entered into a deferred prosecution agreement (“DPA”) and agreed to pay over $85.2 million to resolve DOJ FCPA charges stemming from bribery payments to Venezuelan government officials to secure preferential access to U.S. dollars in a currency auction. Telefónica Venezolana entered into a three-year DPA and the filing of a...

Featured Articles:

DOJ Indicts Indian Billionaire and Seven Other Individuals for Bribery and Fraud Scheme Involving Payments to Indian Government Officials to Obtain Solar Energy Contracts

Lessons Learned from McKinsey’s FCPA Enforcement Action — Local Partners and Third Parties (Part III of III)

McKinsey Company’s Bribery Scheme — A Familiar Pattern in South Africa (Part II of III)

McKinsey Company Pays $122 Million to Resolve FCPA Violations in South Africa (Part I of III)

Antitrust Division Revises Evaluation of Corporate Compliance Programs in Criminal Antitrust Investigations

DOJ Indicts Indian Billionaire and Seven Other Individuals for Bribery and Fraud Scheme Involving Payments to Indian Government Officials to Obtain Solar Energy Contracts

Lessons Learned from McKinsey’s FCPA Enforcement Action — Local Partners and Third Parties (Part III of III)

McKinsey Company’s Bribery Scheme — A Familiar Pattern in South Africa (Part II of III)

McKinsey Company Pays $122 Million to Resolve FCPA Violations in South Africa (Part I of III)

Antitrust Division Revises Evaluation of Corporate Compliance Programs in Criminal Antitrust Investigations

Episode 349 — The BIT Mining FCPA Settlement

BIT Mining FCPA Settlement and Lessons Learned (Part III of III)

BIT Mining Bribery Scheme — CEO Directed Payments and the Cover-Up (Part II of III)

BIT Mining CEO Indicted for FCPA Violations — Bit Mining Pays $10 Million to Settle DOJ and SEC FCPA Cases (Part I of III)

Episode 348 — Deep Dive into Telefónica DOJ Settlement for FCPA Violations

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