LRN consistently provides high-quality reports and important insights on ethics and compliance trends.  Each year, LRN’s Program Effectiveness Report is anticipated as an important source of cutting-edge ethics and compliance initiatives. LRN’s Code of Conduct Report includes a number of important benchmarks for companies to use as a measure of their compliance programs.  In its most recent report, LRN cites a number of important findings...

In yet another reminder of the scope of Justice Department enforcement powers, and an important demonstration of the risks of non-compliance, the Justice Department and relevant banking agencies announced a $3 billion settlement with TD Bank companies to resolve systemic and pervasive Bank Secrecy Act (“BSA”) and money laundering violations. In addition to the financial settlement, TD Bank US Holding Company (TDBUSH) (together with TDBNA,...

The Justice Department’s global settlement included a significant False Claims Act resolution, resulting in  a second deferred prosecution agreement (“DPA”) for a three-year term.  A criminal information was filed in the District of Massachusetts charging Raytheon with two counts of major fraud against the United States..  Raytheon agreed to pay $147 million to resolve the criminal allegations. DOJ’s settlement includes a civil resolution of charges...

Raytheon’s comprehensive settlement included FCPA violations and failures to make required disclosures to the Defense Department concerning fees and commissions.  This portion of the settlement was filed in the Eastern District of New York. Raytheon formed a joint venture with a French company.  Its bribery scheme involved a subsidiary of the joint venture, Integrated Defense Systems (“IDS”), which was controlled by Raytheon. Between approximately 2012...

Raytheon’s criminal conduct cut across a variety of topics — it is difficult to imagine but Raytheon’s misconduct occurred in separate parts of the company, involving violations of different laws.  Like most cases, I always question initially: What was Raytheon’s corporate culture? What was the tone set by Raytheon’s leadership? middle management? Raytheon’s weak culture appears to have permeated every aspect of the large conglomerate. ...

Raytheon Company (Raytheon) — a subsidiary of defense contractor, RTX (formerly known as Raytheon Technologies Corporation) — agreed to pay over $950 million to resolve the Justice Department’s investigations into: (i) a major government fraud scheme involving defective pricing on certain government contracts; (ii) violations of the Foreign Corrupt Practices Act (FCPA); and (iii) the Arms Export Control Act (AECA) and its implementing regulations, the International Traffic...

Corporate compliance staff often conduct internal site visits and reviews. Since the pandemic and the development of remote technology, compliance officers have reduced the number of site visits. In recent years, compliance staff arre slowly increasing the number of site visits and reviews. These site visits permit compliance staff to review important issues: (1) personnel interviews; (2) transaction testing and vendor reviews; (3) ethics and...

Teva Pharmaceuticals USA Inc. (Teva USA) and Teva Neuroscience Inc. (“Teva”) agreed to pay $450 million to resolve two matters that allege Teva violated the Anti-Kickback Statute (AKS) and the False Claims Act (FCA). Teva is the largest generic drug manufacturer in the United States. The settlement resolved two alleged kickback schemes: Medicare Cost-Sharing Scheme and Copay Assistance Foundations First, Teva has agreed to resolve...

The SEC notched another FCPA settlement, continuing its steady pursuit and resolution of FCPA cases.  In the meantime, the Justice Department has been silent in the FCPA enforcement arena.  In its latest settlement, Moog, Inc. (“Moog”), a New York-based global manufacturer of motion controls systems for aerospace, defense, industrial and medical markets, agreed to pay a civil penalty of $1.1 million and disgorge nearly $600,000,...

October 29, 2024 11 AM EST Sign Up Here Global companies are being challenged with rapidly expanding third-party risks.  Cybersecurity, data privacy, and new technologies, such as artificial intelligence, are exponentially expanding third-party risks.  The traditional constellation of legal and compliance now includes technology risks that require compliance professionals to collaborate with technology partners and build multi-discipline risk mitigation strategies. Volkov Law is honored to...