Category: Podcasts

Episode 157 — A Review of World Acceptance Corp. Settlement with SEC for FCPA Violations

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. In this Episode, Michael Volkov discusses the WAC SEC settlement.

Episode 156 — OFAC Sanctions Enforcement and Screening Errors

OFAC has brought several significant enforcement actions in last two years that are described as the result of “screening errors.” These screening errors are sometimes described as the fault of sanctions screening software or human error. In this Episode, Michael Volkov reviews several OFAC enforcement cases stemming from screening errors, including Apple, Amazon, American Express and Cobham Metelics.

Episode 155 — Tom Fox and Mike Volkov Discuss Governance Lessons from Blue Bell Creameries Listeria Outbreak

On May 1, 2020, Blue Bell pleaded guilty to shipping contaminated ice cream linked to a 2015 listeria outbreak and agreed to pay a fine of $19.5 million ($17.4 million criminal fine and $2.1 million to settle civil false claims act violations).  Blue Bell’s former CEO, Paul Kruse, was separately indicted and charged in seven separate counts for conspiracy and wire fraud for concealing from...

Episode 154 — Artificial Intelligence, Data Risk Management: Interview of Christian Focacci from Steele Compliance Solutions

Steele Compliance Solutions announced the global rollout of its new “Risk Intelligence Data” platform.  Companies are suffering from information overload — with new technologies, companies can manage information to increase efficiency and accuracy in collecting and analyzing information needed for risk management purposes. Risk Intelligence Data involves the hybridization of over 5 million of highly trusted risk and compliance sources worldwide, spanning global financial crime...

Episode 153 — Mighty Amazon Falls to the OFAC Sword

Amazon joins the exclusive club of high-tech OFAC violators.  Last year, Apple settled with OFAC for sanctions violations.  This year, we can add Amazon to the list of OFAC violators. On July 8, 2020, Amazon settled with OFAC for $134,523 for violations of multiple OFAC sanctions programs.  Amazon’s violations stemmed from deficiencies from its sanctions screening processes.  As a result, Amazon provided goods and services:...

Episode 152 — Supreme Court Issues Two Important Decisions on Subpoenas for President Trump’s Financial Records

The Supreme Court, in two important decisions issued on the last day of the Term, rejected Trump and DOJ challenges to a New York Criminal Grand Jury subpoena and several Congressional subpoenas for Trump’s financial records. In a decisive ruling, in Trump v. Vance, the Supreme Court rejected by a 7-2 vote, President Trump’s challenges to a New York State grand jury subpoena.  In a separate case, Trump...

Episode 151 — Tom Fox and Michael Volkov Discuss the Revised FCPA Guidance

On July 2, 2020, DOJ and the SEC issued revised FCPA Guidance.  The Revised Guidance continues to be a valuable document, which contains important discussions of relevant cases, DOJ and SEC policies, and enforcement principles relating to the FCPA. In this Episode, Tom Fox and Michael Volkov discuss the Revised FCPA Guidance and highlight important changes and trends.

Episode 150: Review of Novartis False Claims Act and Anti-Kickback Settlements for $729 Million

Novartis is the new poster-child of corporate misconduct.  In the space of two weeks, Novartis settled domestic False Claims Act and Anti-Kickback violations for $729 million, and settled FCPA violations for foreign bribery for $337 million. In the domestic False Claims Act and AKS cases, Novartis resolved two separate cases: one for illegal payments made to three foundations used to pay for patients’ co-payments in...

Episode 149 — A Deep Dive into the Alexion’s SEC Settlement for $21 Million for FCPA Violations

Notwithstanding the pandemic and remote working arrangements, the Securities and Exchange Commission is continuing to bring FCPA enforcement actions.  In its latest action, the SEC settled with Alexion Pharmaceuticals for $21 million for foreign bribery and books and records violations.  In this Episode, Michael Volkov reviews the Alexion FCPA enforcement action and the lessons learned for compliance professionals.

Corporate Culture: Health and Safety (Part II of II)

Companies face a daunting challenge to reassure and regain trust and integrity with employees.  CEOs should view the current situation as an opportunity to improve a company’s culture by building on the company’s trust and integrity values. Aside from basic economic questions, companies have to ensure that employee health and safety are assured.  In this pandemic era and with the spread of disinformation by politicians,...