Corruption, Crime & Compliance

Featured Articles:

General

9 Jan, 2025

BIS Reaches $180,000 Mitigated Settlement with Indium Corporation Over Illegal Exports to Russia

The U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) recently issued a Final Order against The Indium Corporation of America, citing eleven (11) alleged violations of the Export Administration Regulations (“EAR”) between April 14, 2022, and March 31, 2023. The violations involved unauthorized exports of solder preforms, solder wires, and solder ribbons to Russia. These items, though classified as EAR99, required an export...
General

9 Jan, 2025

OFAC Closes Out Year with String of Enforcement Actions — Aiotec Pays OFAC $14.55 Million to Resolve Iran Sanctions Violations

Despite a relatively slow year in OFAC sanctions enforcement, OFAC closed 2024 with a string of settlements in five cases, including its second in 2024 against an individual defendant. While OFAC had a slow year, DOJ continued to increase its criminal enforcement of sanctions cases against individuals, increasing its prosecutions to 70 in 2024, nearly 30 more than 2023 (42). However, in 2024, DOJ did...
General

8 Jan, 2025

AAR’s Bribery Schemes: Bribery in the Aviation Industry (Part II of II)

AAR, a provider of aviation products and services, engaged in two separate bribery schemes. State-owned entities and government agencies permeate the aviation industry. As a result, FCPA risks are embedded in direct industry activity and related services and suppliers. The AAR case is a perfect example of just how easy it is to engage in bribery in the aviation industry. AAR engaged in two separate...
General

7 Jan, 2025

DOJ and SEC Close 2024 with FCPA Enforcement Action Against AAR Corp; DOJ and SEC Announces Resolution with Deepak Sharma, CEO of AAR Subsidiary (Part I of II)

The Justice Department and the SEC finished 2024 with a coordinated resolution of criminal and civil FCPA charges against AAR Corporation, an Illinois-based provider of aviation products and services. In addition, DOJ unsealed a criminal indictment and guilty plea dated August 1, 2024, by Deepak Sharma, CEO of an AAR Subsidiary for his role in the FCPA scheme. Also, the SEC entered into a separate civil...
General

6 Jan, 2025

OFAC Designates Gazprombank for Inclusion on SDN List

By: Daniela Melendez, Associate at The Volkov Law Group, and Alex Cotoia, Regulatory Compliance Manager. Daniela can be reached at [email protected] and Alex can be reached out at [email protected]. In a significant development underscoring the U.S. government’s continued efforts to counter Russia’s destabilizing activities, the U.S. Department of the Treasury recently announced the designation of Gazprombank as a Specially Designated National (“SDN”) under Executive Order 14024. This action,...

9 Jan, 2025

BIS Reaches $180,000 Mitigated Settlement with Indium Corporation Over Illegal Exports to Russia

The U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) recently issued a Final Order against The Indium Corporation of America, citing eleven (11) alleged violations of the Export Administration Regulations (“EAR”) between April 14, 2022, and March 31, 2023. The violations involved unauthorized exports of solder preforms, solder wires, and solder ribbons to Russia. These items, though classified as EAR99, required an export...

General

9 Jan, 2025

OFAC Closes Out Year with String of Enforcement Actions — Aiotec Pays OFAC $14.55 Million to Resolve Iran Sanctions Violations

Despite a relatively slow year in OFAC sanctions enforcement, OFAC closed 2024 with a string of settlements in five cases, including its second in 2024 against an individual defendant. While OFAC had a slow year, DOJ continued to increase its criminal enforcement of sanctions cases against individuals, increasing its prosecutions to 70 in 2024, nearly 30 more than 2023 (42). However, in 2024, DOJ did...

General

8 Jan, 2025

AAR’s Bribery Schemes: Bribery in the Aviation Industry (Part II of II)

AAR, a provider of aviation products and services, engaged in two separate bribery schemes. State-owned entities and government agencies permeate the aviation industry. As a result, FCPA risks are embedded in direct industry activity and related services and suppliers. The AAR case is a perfect example of just how easy it is to engage in bribery in the aviation industry. AAR engaged in two separate...

General

7 Jan, 2025

DOJ and SEC Close 2024 with FCPA Enforcement Action Against AAR Corp; DOJ and SEC Announces Resolution with Deepak Sharma, CEO of AAR Subsidiary (Part I of II)

The Justice Department and the SEC finished 2024 with a coordinated resolution of criminal and civil FCPA charges against AAR Corporation, an Illinois-based provider of aviation products and services. In addition, DOJ unsealed a criminal indictment and guilty plea dated August 1, 2024, by Deepak Sharma, CEO of an AAR Subsidiary for his role in the FCPA scheme. Also, the SEC entered into a separate civil...

General

6 Jan, 2025

OFAC Designates Gazprombank for Inclusion on SDN List

By: Daniela Melendez, Associate at The Volkov Law Group, and Alex Cotoia, Regulatory Compliance Manager. Daniela can be reached at [email protected] and Alex can be reached out at [email protected]. In a significant development underscoring the U.S. government’s continued efforts to counter Russia’s destabilizing activities, the U.S. Department of the Treasury recently announced the designation of Gazprombank as a Specially Designated National (“SDN”) under Executive Order 14024. This action,...

Podcasts

6 Jan, 2025

Episode 350 — Deep Dive into McKinsey FCPA Settlement

What went wrong when McKinsey paid bribes to secure consulting contracts with South Africa’s state-owned enterprises? In this episode, Michael Volkov dives into the December 2024 DOJ settlement with McKinsey & Company, which paid $122 million after being found guilty of paying bribes to officials at Transnet and Eskom to secure valuable consulting contracts. The case involved significant violations of the Foreign Corrupt Practices Act...

General

24 Dec, 2024

Happy Holidays and Happy New Year!

Happy holidays to all our clients, colleagues, family and friends. Our blog, podcasts and webinars will be back on January 6, 2025. We appreciate all the support and look forward to a great year in 2025.

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.,...

Featured Articles:

BIS Reaches $180,000 Mitigated Settlement with Indium Corporation Over Illegal Exports to Russia

OFAC Closes Out Year with String of Enforcement Actions — Aiotec Pays OFAC $14.55 Million to Resolve Iran Sanctions Violations

AAR’s Bribery Schemes: Bribery in the Aviation Industry (Part II of II)

DOJ and SEC Close 2024 with FCPA Enforcement Action Against AAR Corp; DOJ and SEC Announces Resolution with Deepak Sharma, CEO of AAR Subsidiary (Part I of II)

OFAC Designates Gazprombank for Inclusion on SDN List

BIS Reaches $180,000 Mitigated Settlement with Indium Corporation Over Illegal Exports to Russia

OFAC Closes Out Year with String of Enforcement Actions — Aiotec Pays OFAC $14.55 Million to Resolve Iran Sanctions Violations

AAR’s Bribery Schemes: Bribery in the Aviation Industry (Part II of II)

DOJ and SEC Close 2024 with FCPA Enforcement Action Against AAR Corp; DOJ and SEC Announces Resolution with Deepak Sharma, CEO of AAR Subsidiary (Part I of II)

OFAC Designates Gazprombank for Inclusion on SDN List

Episode 350 — Deep Dive into McKinsey FCPA Settlement

Happy Holidays and Happy New Year!

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)

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