Honeywell UOP (“Honeywell”) is a U.S.-based subsidiary of Honeywell International, Inc.  The settlement resolved bribery charges in the United States and Brazil stemming from bribes paid to high-ranking officials at Petrobras, Brazil’s state-owned oil company. Honeywell agreed to a three-year deferred purchase agreement (“DPA”), which was filed in the Southern District of Texas (Houston).  Honeywell agreed to pay approximately $79 million in exchange for the...

The Justice Department and the Securities and Exchange Commission bounced back in 2022 to restore their records for aggressive FCPA enforcement.  At the same time, DOJ announced significant new compliance program expectations, and appeared ready to press forward with a number of FCPA resolutions. Tom Fox, the Compliance Evangelist and Leader of the Compliance Podcast Network, joins Michael Volkov for a comprehensive review of 2022...

The FTX scandal has sent (and is continuing to send) shockwaves through the  cryptocurrency industry.  FTX was one of the largest crypto exchanges in the world, and its CEO, Sam Bankman-Fried (SBF) was the darling of Silicon Valley and Wall Street.  SBF touted FTX for its rapid growth as a crypto exchange and its deep connections to politicians, athletes and movie stars.  It turned out...

In 2020, Asante Berko settled his FCPA case with the SEC by agreeing to pay $329,000. In November of 2022, Berko arrived in London at Heathrow Airport and he was arrested. Berko had no idea that he had been indicted back in 2020 and the indictment remained under seal until he arrived, two years later, at Heathrow Airport. Berko was charged with conspiring with two...

This week’s show discusses recent developments in the sphere of export controls and sanctions. Alexander Cotoia, Regulatory Compliance Manager at the Volkov Law Group, joins Michael Volkov to explore the the Department of Commerce’s Bureau of Industry and Security (“BIS”) ramping up of export control enforcement, including the new restrictions on China and Russia. In early October, the BIS announced two rules imposing significant export...

Oracle Corporation settled its second FCPA case in ten years. It agreed to pay the SEC $23 million to resolve allegations that its subsidiaries in Turkey, India and the United Arab Emirates maintained slush funds to bribe foreign officials. Ten years ago in 2012, Oracle paid the SEC $2 million for creating millions of dollars in off-the-books accounts at its India subsidiary. Join Michael Volkov...

The Episode is available HERE. Matt Stankiewicz, a Partner at Volkov Law, is a leading industry expert on cryptocurrency.  Bittrex, a leading cryptocurrency exchange, suffered twin enforcement actions for AML and Sanctions Compliance deficiencies.  Matt takes a deep dive on the enforcement actions and outlines practical compliance steps that every cryptocurrency exchange should implement.   The Episode is available HERE. Corruption Crime and Compliance is available...

Episode 251 is available here. Maria D’Avanzo is the Chief Evangelist Officer at Traliant.  Maria provides key insights on corporate ethics and compliance training programs.  Maria describes how to take your training program to the next level and tailor the content to deliver training on important issues based on your company’s risk assessment. In this Episode, Mike and Maria discuss compliance training, culture and new...