Category: General

Quad/Graphics Settles SEC FCPA Case for Nearly $10 Million

Quad/Graphics, a Wisconsin print and digital marketing company agreed to pay the SEC almost $10 million to settle FCPA charges for foreign bribery violations in Peru and China. (Here).  Quad/Graphics also violated OFAC sanctions violations for transactions involving a Cuban telecommunications company.  The Justice Department declined to prosecute Quad/Graphics under its FCPA Corporate Enforcement Policy (Here). During the period of 2011 to 2016, Quad/Graphics failed...

Barclays Agrees to Pay the SEC $6.3 Million to Settle FCPA Offenses for Hiring of Relatives of Foreign Officials in Asia

Barclays joined the club of global financial institutions settling FCPA violations for hiring of relatives of foreign officials in Asia.  Barclays agreed to disgorge $3.8 million and paid prejudgment interest of nearly $1 million and a $1.5 million civil penalty. As outlined in the SEC settlement order (here), Barclays Asia Pacific Region hired 117 job candidates referred by or connected to foreign government officials or...

Cooperating Cognizant COO Pays $50K to Settle SEC FCPA Action

In an interesting SEC FCPA settlement action, Sridhar Thiruvengadam, the former COO of Cognizant Technology, agreed to pay a $50K penalty for his role in the bribery scheme involving the payment of $2 million to a government official in India in exchange for the issuance of a planning permit needed for the construction of Cognizant’s new office location in Chennai, India.  Early this year, Cognizant...

UK Bank Agrees to Pay $4 Million to Settle OFAC Sudanese Sanctions Violations

Last week, British Arab Commercial Bank (BACB), located in the United Kingdom, agreed to settle an OFAC enforcement action for $4 million.  (Here and Here).  BACB has no presence in the United States but was cited for processing 72 transactions in violation of the Sudanese Sanctions Regulations. In reaching the settlement, OFAC reduced significantly the penalty amount of approximately $228 million under OFAC Enforcement Guidelines...

Fixing a Toxic Corporate Culture

We all know about the high-profile scandals that lawyers and compliance officers point to as examples of weak to non-existent ethical corporate cultures.  The case studies read like a train wreck, where everything goes wrong, controls are circumvented, crimes are committed with impunity and gatekeepers and lines of defense are either ignored or co-opted into the misconduct.  Almost every story includes failures of oversight by...

Corporate Board Strategies for Monitoring and Promoting a Company’s Ethical Culture (Part III of III)

Corporate boards all want to believe that their companies maintain an ethical culture.  Each board members knows the right words, platitudes and buzz words to use.  No one can fault them there.  But like every issue in life, when push comes to shove, what actual commitment of time and effort do board members actually devote to the specific issue?  And if they do commit to...

Assent’s Supply Chain Risk Conference

Assent Compliance is proud to introduce Supply Chain Insight. This two-day conference inspires supply chain and compliance professionals from around the world through education and networking. Subject matter experts and thought leaders in product compliance, corporate social responsibility and vendor management will share insights to drive innovation and efficiency in your supply chain programs. Join me at the Supply Chain Insight conference this November as...

Living in the Cloud: Practical Approaches to Cybersecurity Risks (Part III of III)

I always loved Tarzan movies, especially the movies starring Johnny Weissmuller as Tarzan.  (Here is a sample).  Tarzan always had a nice house, a great tree house with vines swings for diving and jumping into the water. In the 1990s, Bill Gates of Microsoft fame correctly predicted that computing power and capabilities would eventually move from the desktop to the Internet.  In essence, Gates was...

Bringing the Board to the Ethical Culture Table (Part II of III)

I guarantee you if you ask your corporate board to define “ethical culture” and “compliance,” and their actual day-to-day responsibilities in this area, you will quickly realize most board members have no clue.  This is not a controversial statement because corporate board members, for the most part, are clinging to old ways when it comes to board responsibilities – focus on the financials, monitor your...

The Business Roundtable’s Restatement of Corporate Purpose: A Big Step or a Fig Leaf? (Part I of III)

It is curious that physical courage should be so common in the world and moral courage so rare.  Mark Twain Frankly, I have to admit my reaction to the recent Business Roundtable’s issuance of a new Statement on the Purpose of a Corporation, which was signed by 181 CEOs who committed to lead their companies for the benefit of all stakeholders – customers, employees, suppliers,...