We all know it when we see it – a recurring fact pattern in which a company enlists a corrupt third party intermediary for one purpose (and one purpose only) – to pay a bribe. Let me give you a few examples. Cognizant Technology In the Cognizant Technology FCPA enforcement action, the former President and General Counsel directed the scheme with two other C-Suite officers...
The Justice Department announced a major expansion of its ongoing investigation and prosecution of executives and employees in the boiler chicken price-fixing conspiracy. DOJ recently returned a superseding indictment adding six new defendants to the boiler chicken conspiracy indictment, and expanding the scope of the charged conspiracy. (Here for earlier Posting on conspiracy). The new indictment charges ten (10) executives and employees at boiler chicken...
The former deputy finance chair of the Republican National Committee and prominent fundraiser for President Trump has agreed to plead guilty with lobbying on behalf of Jho Low, an indicted and fugitive financier, who was charged in the ongoing 1MDB sovereign wealth fund investigation and prosecution. Broidy agreed to assist Jho Low by lobbying the Justice Department and administration and failed to register as required...
We are proud to announce the addition of a new sponsor — Blue Umbrella, a leading provider of due diligence research and innovative third-party compliance technologies. Combining global research excellence with disruptive RegTech SaaS solutions, Blue Umbrella serves multinational corporations working in technology, manufacturing, life sciences, defense/aerospace, agriculture, energy, finance, and consumer goods as well as top-tier investment banks. With a global presence and local...
By any measure, the SEC’s whistleblower program has been a success. Since its inception about 10 years ago, the SEC has collected $2.5 billion in financial recoveries based on whistleblower tips. A large portion of this money has been returned to victim investors. Section 922 of the Dodd-Frank Wall Street Reform and Consumer Protection Act added Section 21F to the Securities Exchange Act of 1934...
OFAC continues to chalk up enforcement actions. For the year, even with the pandemic slow down, OFAC has reached 13 settlement agreements totaling $18.6 million in penalties. In its latest enforcement settlement, Generali Global Assistance, Inc. (“GGA”), a US-based travel assistance services company that provides travel and claims services on behalf of clients that offer global medical expense and travel insurance policies, agreed to pay...
JP Morgan Chase (“JP Morgan”) is not having a positive year when it comes to government enforcement. JP Morgan is at the brink of a multi-billion dollar FCPA settlement for its involvement in the 1MDB corruption scandal in Malaysia. Add to this a few regulatory enforcement actions: an SEC settlement for manipulative trading U.S. Treasury securities; and a FINRA fine of $1.1 million for failure...
If you speak to members of a corporate board and the C-Suite and you ask them if the company has a strong ethical culture, we all know what they will say – “Of course, we do. We have a strong commitment to our Code of Conduct and Doing the Right Thing . . . . [blah blah blah].” You can listen, nod your head and...
NAVEX Global has announced its upcoming virtual ethics and compliance conference. ( Formerly the Ethics & Compliance Virtual Conference (ECVC)). NAVEX’s upcoming conference theme is: Beyond the Moment. Sign Up HERE. NAVEX Global’s annual virtual conference is a terrific opportunity to catch up with the latest ethics and compliance trends and stay proactive in the field. NAVEX Global’s goal this year is to help everyone be...
Boeing’s culture and safety performance continues to undermine its ability to move forward and regain trust from regulators, the aviation industry and the flying public. Boeing has to undergo transformative change. All indications of reform are sparse and Boeing appears to be moving slowly but not so effectively to implement real and substantial reforms. Boeing faces significant challenges to the core of its culture and...
