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...

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...