Bureau van Dijk, a Moodys Analytics Company, recently released a new white paper, What you need to know about sanctions compliance. You can download the white paper here. I was pleased to contribute to the white paper and hope you find it helpful.

Samsung’s recent FCPA settlement with the Justice Department capped yet another example of a company involved in bribing Petrobas in Brazil for valuable contracts.  The scope of the bribery scheme was focused on a contingent deal involving Samsung’s desire to build a drillship for Chartering Company in Houston, Texas.  Beginning in 2007 and continuing until 2013, Samsung conspired with others  to violate the FCPA by...

Samsung Heavy Industries agreed with the Justice Department to pay $75 million to settle FCPA charges. Under a three-year deferred prosecution agreement (DPA), Samsung agreed to filing of a criminal information in the Eastern District of Virginia charging the company with FCPA conspiracy. DPA Copy Here. Over a six-year period, Samsung carried out a bribery scheme to pay millions of dollars to Petrobas in Brazil...

We all take notice when government employees from enforcement agencies engage in wrongdoing.  It is important, however, for credibility that government agencies investigate themselves and prosecute employees for wrongdoing.  Otherwise, a government agency can lose credibility as an honest broker.  The Justice Department recently announced criminal charges against a former SEC examiner who allegedly engaged in wrongdoing when he left the SEC to work at...

Last week, DOJ announced the indictment of two former Herbalife executives in China for participating in a bribery scheme over a ten-year period.  Herbalife, a multi-level marketing company, was not charged and its investigation is ongoing. The criminal; indictment, which was returned in the Southern Dustrict of New York, charges Yangling Li, aka Jerry Li, and Hongwei Yang, aka Mary Yang.  Li was the former...

Lawrence Hoskins, a UK citizen and former Alstom executive, was convicted last Friday on 11 of 12 counts for his role in a bribery scheme involving Indonesian officials. Hoskins conviction took years to secure because of jurisdictional challenges and appeals.  Hoskins was originally indicted in 2013.  Alstom itself settled FCPA charges at the end of 2014 and agree to pay roughly $770 million.  Three other...

Last month, the California Attorney General released draft regulations for the California Consumer Privacy Act (CCPA).  (Here). The regulations focus on three primary areas: (1) consumer notices; (2) consumer requests for information and handling of information; and (3) verification requirements. The implementation date for the CCPA is January 1, 2020.  The deadline for submission of comments is December 6, 2019.  The regulations will not become...

The Justice Department and the SEC have launched criminal and civil accounting fraud investigations against Under Armour.  The sportswear maker has been suffering a rapid revenue decline over the last few years.  The allegations focus on Under Armour’s accounting practices and shifting of sales from quarter to quarter to present a healthier picture of its finances than was actually occurring. Under Armour Culture Problems Over...

The Financial Industry Regulatory Authority is not known for its aggressive enforcement record.  But that may be changing. FINRA recently fined BNP Paribas for $15 million for anti-money laundering deficiencies in the broker-dealer unit’s operations that allowed billions of dollars’ worth of suspicious penny stock and foreign currency transactions. BNP’s senior management failed to respond to repeated warnings from staff that the firm’s minimal AML...

Two charitable foundations that helped patients pay for drug co-payments settled anti-kickback charges for $6 million.  The Patient Access Network Foundation (PANF) agreed to pay $4 million and Good Days agreed to pay $2 million to resolve AKS allegations.  The charitable foundations were used as pass throughs for Denderon, Astellas, Amgen and other drug companies to funnel money to Medicare patients taking their drugs.  The...