Category: General

General

11 Aug, 2020

World Acceptance Corporation Settles FCPA Charges with the SEC for $21.7 Million

World Acceptance Corporation (“WAC”), a US-based consumer loan company, agreed to pay the SEC $21.7 million for FCPA violations in Mexico.  WAC’s cited violations covered the full gamut of FCPA violations, including bribery payments to government officials in Mexico, failure to keep accurate books and records and inadequate internal accounting controls. WAC engaged in an illegal scheme over a seven year period, from December 2010...

General

10 Aug, 2020

The Demand for Organizational Justice

Companies do not operate in a vacuum.  Political and social forces have a dramatic impact on individuals who in turn constitute a company’s workforce.  We are witnessing significant political forces demanding justice for historical and engrained racism, sexism, injustice and discrimination.  A significant majority of Americans have embraced the Black Life’s Matter movement and with that have demonstrated an increased demand for social justice. This...

General

7 Aug, 2020

Valeant Pharmaceuticals (Now Bausch Health) and Three Former Executives Settle SEC Cases

Bausch Health agreed to pay the SEC $45 million to settle Valeant Pharmaceuticals (former name) accounting fraud schemes.  Three former executives, former CEO Michael Pearson, CFO Howard Schiller and Controller Tanya Carro also settled with SEC.  Pearson agreed to pay a civil penalty of $250,000 and repaid Bausch $450,000 in compensation; Schiller agreed to pay a civil penalty of $100,000 and repaid Bausch $110,000 in...

General

6 Aug, 2020

Apple and Amazon Fall to OFAC Enforcement for “Screening Errors” (Part III of III)

It is hard to argue that Apple and Amazon do not have the resources to implement state-of-the-art OFAC compliance programs. After all, the two largest companies in the world should stand as beacons of compliance with the full support of senior management, robust compliance departments, and sophisticated automated systems to support their compliance efforts.  Apple Even the mighty can fall – Apple agreed to pay...

General

5 Aug, 2020

OFAC Enforcement Cases Focused on “Screening Errors”: American Express and Cobham Metalics (Part II of III)

In the last two years, OFAC has brought four enforcement actions that focus on an organization’s “screening errors.” These include: American Express; (2) Cobham Metalics; (3) Apple; and (4) Amazon. In today’s posting, I will review American Express and Cobham Metalics. American Express On April 30, 2020, OFAC issued a Finding of Violation (with no penalty) against American Express Travel Services for violations of  the...

General

4 Aug, 2020

OFAC Enforcement and “Screening Errors” (Part I of III)

Here is another profound grasp of the obvious (for which I have a knack for delivering) – compliance and legal professionals can learn a number of lessons from individual enforcement actions.  In many cases, however, there is much more to the story than the headline or the list of so-called lessons learned. One category of enforcement actions is a perfect example – OFAC has brought...

General

3 Aug, 2020

OFAC On A Roll: Whitford Worldwide Company Agrees to Pay $824k for Violations of Iran Sanctions

When you are hot, you are hot.  (And when you are not, you are not; Thank you Jerry Reed, Country Singer).  OFAC is hot and resumed its enforcement streak, settling three enforcement actions in three weeks.  The latest settlement involved Whitford Worldwide Company (Whitford”), a cookware manufacturer based in Pennsylvania, which agreed to pay $824,314 for violations of the Iran Sanctions.  Whitford’s liability stemmed from...

General

30 Jul, 2020

Oklahoma City Hospital, Management Company, And Physician Group To Pay $72.3 Million To Settle Federal And State False Claims Act

The Justice Department’s enforcement programs are resuming – False Claims Act, FCPA and other programs will continue.  The rate of enforcement, however, is subject to change once again from the impact of the pandemic. As the pandemic continues to spread, DOJ focus on pandemic related fraud and other scams will divert resources from “traditional” priorities. DOJ’s commitment to False Claims Act prosecutions in the health...

General

29 Jul, 2020

Indivior Solutions Pleads Guilty to False Statements and Agrees to Pay $600 Million to Resolve Criminal and Civil investigations for Marketing of Opioid Addiction Treatment Drug Suboxone

DOJ’s aggressive enforcement of the opioid industry is a striking example of the power of federal prosecutors when focused on an industry.  Once prioritized for enforcement, DOJ has quickly brought together prosecutors and law enforcement to target corporate actors and companies with the full force of criminal and civil statutes. In a significant case, DOJ announced the resolution of its criminal and civil investigations against...

General

28 Jul, 2020

DOJ Criminal Generic Pharma Price-Fixing Investigation Gathers Steam: Taro Pharmaceuticals Agrees to Pay DOJ Total of $419 Million

The DOJ Antitrust Division’s multi-year criminal cartel investigation of the generic pharmaceutical industry is gaining steam.  The latest company to settle is Taro Pharmaceuticals which agreed to enter a deferred prosecution agreement and pay a $205.7 million penalty to resolve charges relating to a criminal price-fixing conspiracy.  The Antitrust Division’s settlement with Taro is the 10th case, and the 6th company to be charged or...

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