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...

Boeing is the new poster child for corporate governance failures and misconduct.  Move over Wells Fargo, General Motors, Volkswagen, Novartis, Siemens and Wal-Mart, and make room for Boeing.  Like General Motors and its ignition switch scandal, innocent consumers were killed as a direct result of corporate governance failures and blatant misconduct. Boeing’s 737 MAX was rolled off the factory floor with fanfare and great expectations...

OFAC is a steady enforcement agency.  As the COVID-19 pandemic settled down, OFAC resumed aggressive enforcement of economic sanctions.  In its latest action, OFAC announced a settlement with Keysight Technologies (“Keysight”), a Santa Rosa, California, for conduct stemming from its former subsidiary, Anite Finland (“Anite”) for re-exports of US export-controlled test measurement equipment to Iran.  In a familiar fact pattern surrounding OFAC compliance and acquisitions,...

The Justice Department announced a guilty plea to FCPA charges by Sargeant Marine, Inc., a privately-owned company, based in Boca Raton, Florida.  Sargeant Marine, an asphalt company, plead guilty to one count of conspiracy to violate the anti-bribery provisions of the FCPA and agreed to pay a fine of $16.6 million for bribery schemes in Brazil, Venezuela and Ecuador.  Between 2010 and 2018, Sargeant Marine...

A federal grand jury in the Eastern District of New York returned an indictment against Javier Aguilar, an oil trader at Vitol, an energy and commodity trading company, for his role in a five-year international bribery and money laundering scheme carried out in Ecuador. Between approximately 2015 and July 2020, Aguilar and others participated in a conspiracy to pay and conceal bribes to Ecuadoran government...

Watching the compliance industry and advocating for the compliance profession can be frustrating.  Corporate boards and senior management know the importance of committing to a culture of compliance.  To accomplish that task requires focus, determination and commitment. Words are words but actions are tangible.  In the end, corporate boards and senior management have to act and commit to promote the importance of compliance.  As I...

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