We should all admit something (among many things) — reading through factual statements of bribery offenses, the facts all start to meld together. Criminals are not as ingenuous or creative as they think, and the schemes they employ are fairly straightforward. Let’s start with one profound grasp of the obvious — To pay bribes, criminals have to “steal” money from the company, that is, they...
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...
The Justice Department is about to undergo some fundamental changes. The 2nd Trump Administration will take some initial broad strokes designed to increase accountability and control of prosecutors and laws enforcement. The FBI The first on the chopping block is the FBI. Under existing law, the FBI is a component of the U.S. Department of Justice, presumably under the control and oversight of the Attorney...
The 2nd Trump Administration will mean significant change in foreign policy, most especially the importance of ending the Russia-Ukraine war, increased focus on Iran and its proxies, and aggressive use of trade policies and tools to execute the policy and promote United States businesses. Since the start of the Russia-Ukraine war and the unprecedented global sanctions and export controls regime, trade enforcement and compliance have...
As the dust settles on the U.S. Election, companies are quickly analyzing the impact for businesses, federal civil and criminal enforcement priorities and the implications for ethics and compliance. When a new Administration comes into power, change is inevitable and can be far-reaching. Given the change with President Trump’s return to the White House, and in light of several of his stated intentions, companies should...
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]. North Korea Sanctions Violations In a recent enforcement action, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) imposed an $860,000 penalty on Vietnam Beverage Company Limited (“VBCL”), a holding company based in Vietnam, for apparent...
On November 1, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) imposed a $500,000 monetary penalty on GlobalFoundries U.S. 2 LLC and its parent, GlobalFoundries U.S. Inc., for a series of unauthorized exports to SJ Semiconductor (“SJS”), a restricted party contained on BIS’s ubiquitous Entity List. This recent enforcement action reflects BIS’s steadfast commitment to enforcing U.S. export controls, especially in...
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...
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...
