In a record year, there are bound to be numerous interesting enforcement actions and principles. I picked out a few to highlight. It is surprising to say the least that DOJ continues to return large enforcement actions against a number of global companies. You would think after the last ten years of aggressive enforcement companies would refrain from bribery schemes or dedicate resources to cleaning...
Happy New Year!! In the FCPA arena, 2019 was a record year – in enforcement and compliance. Many continuing trends are becoming more than trends – meaning they are turning into established practices. Enforcement First, let’s start with the numbers. DOJ settled 7 enforcement actions and issued declinations in two cases. The seven cases involved MTS Telesystems, Fresenius, Walmart, Technip/FMC, Microsoft, Samsung and Ericsson. The...
The Volkov Law Group is pleased to announce that Elizabeth (“Liz”) Slim has joined the firm as a Senior Consultant. Liz can be reached at [email protected]. Liz has been a Certified Anti-Money Laundering Specialist (“CAMS”) for 15 years; she has over thirty-five (35) years specializing in bank operations, compliance, risk management and regulatory training at various community to mid-size financial institutions. For the last fifteen...
To all of our clients, readers, subscribers, listeners, from everyone at The Volkov Law Group wishes you Happy Holidays and a Happy New Year!! We will resume our blog, podcasts and webinars with the new year — on January 2, 2020. Best wishes to all — Mike, Jessica, Matt, and Noah.
The Treasury Department’s Office of Foreign Asset Control (“OFAC”) continues to rack up settlements. Two travel insurance companies recently settled OFAC enforcement actions for violations of the Cuban Embargo. Allianz Global Risks Allianz Global Risks US Insurance Company (“AGR US”) is the US subsidiary of the German financial company. AGR US operates AGR Canada as a branch office in Toronto, Canada. AGR US agreed to...
Jessica Sanderson, Of Counsel at The Volkov Law Group, rejoins us for a posting on gift-giving, the holiday season and compliance messaging. Jessica can be reached at [email protected]. As the holidays quickly approach, consider sending a message from the Board or senior management reminding employees about your gift and hospitality policy. DOJ Guidance highlights tailored communications as a “hallmark” of any well-designed compliance program, and...
Global companies are paying greater attention to criminal antitrust risks – and with good reason. We often dwell on the impact to a company of a major FCPA investigation. A global criminal antitrust investigation often in destabilizing given the mature global enforcement environment. Cartel members often have to respond to multiple jurisdictions to resolve their potential liability. In early December 2019, after a four-week trial,...
Boston Heart Diagnostics, a Massachusetts company, agree to pay $26.7 million to settle a False Claims Act case involving allegations of paying illegal kickbacks to physicians. According to the settlement, Boston Heart charged Medicare and Medicaid patients for advanced lipid testing referred by providers who received kickbacks from independent marketers at the direction of Boston Heart. Starting in 2015, Boston Heart provided advanced lipid testing...
Corporate cultures do not operate in a silo or free from external influences. Yet again, another profound grasp of the obvious. Employees, managers and senior leadership all bring their own experiences, perspectives, attitudes and influences. Of course, our political and social environment is a consistent and steady influence on corporate culture and behavior. Given the current social climate, the divisive nature of our politics, particularly...
Ericsson’s FCPA settlement is in the books (not the books and records). But it casts a significant shadow across the FCPA landscape. A pervasive and systemic culture of bribery is defined to reflect senior executive involvement, winning business at any cost and using bribery as an accepted business strategy. Ericsson will now pay more than just the price of a $1 billion settlement; it will...
