Category: Podcasts

Episode 209 — Schlumberger Settles Two OFAC Enforcement Actions

In a pair of enforcement actions, OFAC settled two separate actions involving Schlumberger Limited subsidiaries – the first involving Cameron International Corporation, and the second, Schlumberger Rod Lift, Inc., a former subsidiary, that was acquired by Lufkin Rod Lift, Inc. In this Episode, MIchael Volkov reviews the two OFAC enforcement actions.

Episode 208 — A Review of the WPP SEC FCPA Enforcement Action

WPP, the Largest Global Advertising Group, Settles FCPA Charges with SEC for $19.2 Million. After a long hiatus, the SEC announced a settlement with WPP plc, the world’s largest advertising group, for FCPA violations in India, China, Brazil and Peru for $19.2 million. The SEC’s resolution charges WPP with violations of the anti-bribery, books and records and internal accounting controls provisions of the FCPA. In this...

Episode 207 — Common Pitfalls in Conducting Internal Investigations

An internal investigation is like reading a good novel.  You begin the journey with a general expectation of what the novel or the “investigation” is about.  As you learn more, the investigation gains momentum filled with moments of discovery, surprise and ultimately a basis for understanding.  In some cases, the end of the story (e.g. an oil well explosion) or dramatic event is known.  In...

Episode 206 — Update on Sanctions Compliance and Enforcement

The Department of Treasury’s Office of Foreign Asset Control (“OFAC”) continues to bring sanctions enforcement actions.  At the same time, OFAC is reiterating the importance of sanctions compliance program.  Building on its May 2019 Framework for Sanctions Compliance Program, OFAC is sticking to its word — setting forth sanctions compliance program requirements and holding companies accountable for sanctions program violations. In this Episode, Michael Volkov...

Episode 205 — How to Audit a Compliance Program

Chief compliance officers recognize the importance of conducting robust audits of their compliance programs. The audit process requires a delicate balance between qualitative and quantitative measures. As corporate compliance programs build data analytics and technological capabilities, CCOs have to tailor the audit program to incorporate data as an effective measure of a compliance program. In this Episode, Michael Volkov reviews strategies for conducting compliance program...

Episode 204 — “This is the Way” on Corporate Culture

The culture bandwagon is picking up steam.  Everyone is citing its organization’s “culture” as the foundation for its activities in the hope of meeting a rapidly evolving standard for organizations.  In its latest corporate compliance guidance, the Justice Department, along with numerous regulatory agencies continue to cite the importance of a company’s  “culture of compliance.” But when it comes to defining the terms, how to...

Episode 202 — A Deep Dive into the Alfa Laval OFAC Enforcement Action

In two separate enforcement actions, OFAC announced settlements with Alfa Laval Middle East Ltd., a Dubai, UAE company (AL Middle East), and Alfa Laval, Inc., a Virginia-based company (AL US) for violations of OFAC’s Iran Sanctions Program. AL US enlisted its then subsidiary (now operating unit), Alfa Laval Tank, Inc, based in Exton, Pennsylvania (AL Tank), to participate in the scheme.  The Alfa Laval enforcement...

Episode 201 — DOJ Brings Flurry of False Claims Act Cases

The False Claims Act is a powerful enforcement tool.  The Justice Department with its partner agencies are ramping up enforcement efforts.  The Biden DOJ is preparing to implement an aggressive FCA program across healthcare, defense industries and other government contractors.     The False Claims Act stands as a major risk – businesses that depend on government business, including healthcare, defense and other contractors, have to address...

Episode 200 — The Foster Wheeler FCPA Enforcement Action

The Justice Department and the Securities Exchange Commission are back in business.  The first corporate FCPA enforcement action in 2021 came after a six-month hiatus in 2021. The first case against a corporate entity in 2021 is an interesting one because it reflects a coordinated settlement not only between DOJ and the SEC but the U.K.’s Serious Fraud Office and Brazil’s Ministério Público Federal (MPF),...