In a blockbuster case, the Justice Department announced a global settlement with Airbus SE, a manufacturer of civilian and military aircraft, under which Airbus agreed to pay over $4 billion (yes, with a “B”) to resolve charges with the United States, France, and the United Kingdom for its role in a bribery scheme, and to resolve Airbus’ violation of the International Trade in Arms Regulations...

The Justice Department is often criticized for its lack of transparency.  But when it comes to policy changes or initiatives, DOJ is more than transparent – DOJ always tells the public what it plans to do and then does it.  When people act surprised about a policy initiative or a DOJ announcement or speech on a subject, they simply failed to read DOJ’s statements or...

The Office of the Comptroller of Currency (OCC) announced a $17.5 million settlement with former Wells Fargo Bank CEO John Stumpf’s role in the sales practices misconduct scandal.  In addition, the OCC announced settlements with two other Wells Fargo officials: (1) Hope Hardison, former Chief Administrative Officer and Director of Human Resources, Cease and Desist Order and $2.25 million civil money penalty; and (2) Michael...

In this episode, Tom Fox and Mike Volkov begin a three-part series where they discuss the classic movie A Night at the Opera and how it informs 2019 in compliance, FCPA enforcement actions and ethics/compliance trends. The Episode is available Here.

Jessica Sanderson, Of Counsel at The Volkov Law Group rejoins us for her annual review of False Claims Act enforcement. Jessica can be reached at [email protected]. 2020 marks the 150th anniversary of the Department of Justice (“DOJ”), and it unwrapped a nice gift: On January 9, 2020, DOJ released its Fraud Statistics showing that it obtained more than $3 billion under the False Claims Act...

In an interesting end of year decision, issued on December 31, 2019, a District Court in Dallas issued a rejected OFAC’s enforcement action against Exxon Corporation imposing a $2 million penalty for violation of the Russia Sanctions Program.  (Copy of decision is here).  OFAC suffered a rare rebuke after extensive litigation and it will be interesting to see if OFAC appeals the District Court’s decision....

I usually ignore hyperbole.  I cringe when I hear, “[Title] was the greatest movie of all time,” or “[Title] was the greatest book of all time” (true confession — except if someone fills in the blank with The Brothers Karamazov by Fyodor Dostoevsky). Moving on, 2019 was a big year in OFAC compliance.  The Sanctions Compliance Guidance (here) was a major change in sanctions compliance. ...