Corruption, Crime & Compliance

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Events

24 Apr, 2024

Webinar: Effective Strategies to Handle Whistleblower Complaints

Webinar: Effective Strategies to Handle Whistleblower Complaints May 21, 2024, 12 Noon EST Sign Up HERE Whistleblower reporting is a real and pervasive threat to companies. The Justice Department, the Securities and Exchange Commission and other regulatory agencies offer financial rewards to potential whistleblowers. This new incentive structure poses real risks for companies that whistleblowers may skip internal reporting and present concerns to fedferal prosecutors...
General

24 Apr, 2024

NAVEX 2024 Whistleblower Report Highlights Important Trend — More Reports are Being Made and More Are Being Substantiated

NAVEX continues to produce high-quality compliance reports, many of which are a must-read in the compliance industry. Its annual Whistleblower Report is of particular note — NAVEX is the leading provider of hotline services in the world and its data is invaluable as a source of trends in this industry. This year –2024 — is no exception. NAVEX combed through the data from 3784 organizations...
General

22 Apr, 2024

BIS Emphasizes Need for Reinvigorated Due Diligence Efforts by Exporters

Remarks given by Commerce Secretary Gina Raimondo and Undersecretary Alan Estevez during the 2024 Policy Update Conference sponsored by the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) emphasized the need for organizations to enhance their due diligence efforts to prevent the diversion of restricted commodities to U.S. adversaries, including, but not limited to, the Russian Federation and the Islamic Republic of Iran. ...
General

21 Apr, 2024

SCG Plastics Pays OFAC $20 Million to Resolve Violations of Iran Sanctions Program

OFAC is capable of extending a long-arm of enforcement, reaching sometimes non-U.S. companies that may “cause” another company to violate U.S. Sanctions laws. If you need to find an example of this long reach, look no further than last week’s OFAC settlement with SCG Plastics (“SCG”), in which SCG, a Thailand company, which sells plastic resins, agreed to pay $20 million for violations of the...
General

18 Apr, 2024

DOJ Takes Aim At Apple’s Dominance Over Smartphones

The Justice Department has a long and rich history of targeting dominant companies using antitrust monopolization tools — looking back to the 1980s, it was AT&T; in the 1990s, it was Microsoft; and in 2023, DOJ has brought a monopolization case against Google; and meanwhile the FTC filed monopolization cases against Facebook and Amazon. DOJ has now turned to Apple and its dominance in the...

24 Apr, 2024

Webinar: Effective Strategies to Handle Whistleblower Complaints

Webinar: Effective Strategies to Handle Whistleblower Complaints May 21, 2024, 12 Noon EST Sign Up HERE Whistleblower reporting is a real and pervasive threat to companies. The Justice Department, the Securities and Exchange Commission and other regulatory agencies offer financial rewards to potential whistleblowers. This new incentive structure poses real risks for companies that whistleblowers may skip internal reporting and present concerns to fedferal prosecutors...

General

24 Apr, 2024

NAVEX 2024 Whistleblower Report Highlights Important Trend — More Reports are Being Made and More Are Being Substantiated

NAVEX continues to produce high-quality compliance reports, many of which are a must-read in the compliance industry. Its annual Whistleblower Report is of particular note — NAVEX is the leading provider of hotline services in the world and its data is invaluable as a source of trends in this industry. This year –2024 — is no exception. NAVEX combed through the data from 3784 organizations...

General

22 Apr, 2024

BIS Emphasizes Need for Reinvigorated Due Diligence Efforts by Exporters

Remarks given by Commerce Secretary Gina Raimondo and Undersecretary Alan Estevez during the 2024 Policy Update Conference sponsored by the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) emphasized the need for organizations to enhance their due diligence efforts to prevent the diversion of restricted commodities to U.S. adversaries, including, but not limited to, the Russian Federation and the Islamic Republic of Iran. ...

General

21 Apr, 2024

SCG Plastics Pays OFAC $20 Million to Resolve Violations of Iran Sanctions Program

OFAC is capable of extending a long-arm of enforcement, reaching sometimes non-U.S. companies that may “cause” another company to violate U.S. Sanctions laws. If you need to find an example of this long reach, look no further than last week’s OFAC settlement with SCG Plastics (“SCG”), in which SCG, a Thailand company, which sells plastic resins, agreed to pay $20 million for violations of the...

General

18 Apr, 2024

DOJ Takes Aim At Apple’s Dominance Over Smartphones

The Justice Department has a long and rich history of targeting dominant companies using antitrust monopolization tools — looking back to the 1980s, it was AT&T; in the 1990s, it was Microsoft; and in 2023, DOJ has brought a monopolization case against Google; and meanwhile the FTC filed monopolization cases against Facebook and Amazon. DOJ has now turned to Apple and its dominance in the...

General

17 Apr, 2024

DOJ, Commerce and Treasury Issue JCN on Foreign Person Liability for Sanctions and Export Controls Violations

As DOJ, OFAC and BIS ramp up sanctions and export controls enforcement, they have continued to provide important compliance guidance. You have to give the enforcement agencies credit — on the one hand, they regularly warn of the coming enforcement storm and aggressive push against companies and individuals; and on the other hand, they provide significant compliance guidance. Over the last five years, DOJ, OFAC...

Podcasts

14 Apr, 2024

Episode 317 — Deep Dive into Trafigura’s FCPA Settlement

On the heels of the Gunvor FCPA settlement for $661 million, DOJ announced its settlement with Trafigura, the latest commodities trading company to fall under DOJ’s FCPA Sweep against the industry. Trafigura joined the list of international commodity trading companies to suffer FCPA enforcement actions — Vitol, Sargeant Marine, Glencore, Freepoint, and Gunvor. DOJ’s corporate resolutions are connected to individual prosecutions and guilty pleas of...

General

10 Apr, 2024

Lessons-Learned from the Trafigura FCPA Settlement (Part III of III)

The Justice Department is rightly trumpeting its successful sweep of the commodities trading industry. DOJ’s success is reflected in its six separate corporate resolutions and 20 individual convictions, resulting in over $1.7 billion in penalties. Companies in the global commodities trading industry should take heed of DOJ’s focus. Every significant player in the industry, if not under investigation, should audit and review their operations. Those...

General

9 Apr, 2024

Trafigura’s Bribery Scheme: Clandestine Meetings, 3rd Parties and Shell Companies (Part II of III)

Trafigura’s bribery scheme resembles the same schemes implemented by its significant competitors — Vitol, Glencore, Gunvor. At the core of the conduct, Petrobras and Brazilian government officials collected bribes in exchange for valuable contracts for Petrobras oil. The factual statement reflects DOJ’s extensive knowledge base in the international commodity trading industry — DOJ had access to several significant cooperating witnesses, including Petrobras officials and trader...

General

8 Apr, 2024

Featured Articles:

Webinar: Effective Strategies to Handle Whistleblower Complaints

NAVEX 2024 Whistleblower Report Highlights Important Trend — More Reports are Being Made and More Are Being Substantiated

BIS Emphasizes Need for Reinvigorated Due Diligence Efforts by Exporters

SCG Plastics Pays OFAC $20 Million to Resolve Violations of Iran Sanctions Program

DOJ Takes Aim At Apple’s Dominance Over Smartphones

Webinar: Effective Strategies to Handle Whistleblower Complaints

NAVEX 2024 Whistleblower Report Highlights Important Trend — More Reports are Being Made and More Are Being Substantiated

BIS Emphasizes Need for Reinvigorated Due Diligence Efforts by Exporters

SCG Plastics Pays OFAC $20 Million to Resolve Violations of Iran Sanctions Program

DOJ Takes Aim At Apple’s Dominance Over Smartphones

DOJ, Commerce and Treasury Issue JCN on Foreign Person Liability for Sanctions and Export Controls Violations

Episode 317 — Deep Dive into Trafigura’s FCPA Settlement

Lessons-Learned from the Trafigura FCPA Settlement (Part III of III)

Trafigura’s Bribery Scheme: Clandestine Meetings, 3rd Parties and Shell Companies (Part II of III)

Trafigura Joins the FCPA Enforcement Club: Pleads Guilty and Pays Over $126 Million for Bribery Violations in Brazil (Part I of III)

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