Corruption, Crime & Compliance

Featured Articles:

19 May, 2020

Unraveling Beneficial Ownership Risks (Part II of IV)

When discussing the importance of beneficial ownership with compliance professionals, there is often a disconnect between the theory and reality. Everyone understands the legal and compliance risks and how they apply to third-parties, vendors and suppliers. But when a compliance officer considers the burden of uncovering beneficial ownership interests, they quickly resist the need for such an analyses across the population. And for good reason....

General

18 May, 2020

Addressing Beneficial Ownership Requirements in Your Compliance Program (Part I of IV)

We repeatedly hear about the importance of beneficial ownership, and the requirement that companies confirm beneficial ownership of its third-parties, vendors and suppliers. At the same time, there is increasing pressure from regulators and law enforcement to identify and unravel beneficial ownership when dealing with business partners. There is no question that beneficial ownership is a critical issue. I have frequently stated (i.e. repeated myself)...

Podcasts

17 May, 2020

Episode 142: Covid-19: The New Risk and Compliance Framework

The Covid-19 pandemic has had a devastating impact. Businesses have had to adjust rapidly to a new world, filled with significant healthy and safety risks, along with business survival and continuity issues. Companies have reacted with crisis management strategies. As part of this response, companies have to implement a new risk profile and allocate resources accordingly. In this episode, Michael Volkov reviews the new risk...

General

14 May, 2020

In a Unanimous Decision, the Supreme Court Reverses New Jersey Bridgegate Convictions

The Supreme Court continued its clear commitment to trimming aggressive criminal prosecutions in high-profile cases by issuing a unanimous decision reversing the criminal convictions of two Bridgegate convictions in the New Jersey prosecutions of then-Governor Chris Christie’s Administration. The case grew out of former Governor Chris Christie’s 2013 re-election campaign. Bridget Kelly, Christie’s Deputy Chief of Staff, and William Baroni, the Deputy Executive Director of...

General

13 May, 2020

Cancer Treatment Center Agrees to DPA and $100 Million Penalty for Criminal Antitrust Violations in Florida Market

The Justice Department’s Antitrust Division recently announced a $100 million settlement with Florida Cancer Specialists & Research Institute (“FCS”) for an illegal conspiracy to allocate cancer patients in Southwest Florida. FCS conspired with various competitors to allocate medical and radiation oncology treatments. The $100 million criminal penalty is the statutory maximum under Section 1 of the Sherman Act. FCS also reached a settlement with Florida...

General

12 May, 2020

Despite Pandemic, OFAC Settles with Animal Nutrition Company for $257k for Violations of Cuban Sanctions Program

OFAC announced a $257k settlement with Biomin America, Inc. (“Biomin”), an animal nutrition company based in Overland, Kansas, to settle violations of the Cuban Sanctions Program. OFAC recently issued guidance suggesting that organizations may re-allocate or reduce sanctions compliance operations based on the impact of the pandemic on an organization’s business activities. Notwithstanding this guidance, OFAC announced this enforcement action, the first in several months,...

Podcasts

11 May, 2020

Episode 141 — Practical Approaches to Managing Beneficial Ownership Risks (Part II of II)

In a two-part series, Michael Volkov examines the continuing problem of identifying and mitigating beneficial ownership risks. Money launderers and corrupt individuals continue to rely on corporate structures to disguise their ownership interests to further illicit schemes. Companies have to develop strategies that practically address the risks without dedicating disproportionate resources to the problem. In the first episode, Michael Volkov discusses beneficial ownership risks and...

Podcasts

10 May, 2020

Episode 140 — Addressing Beneficial Ownership Interest Risks in Your Compliance Program (Part I of II)

General

7 May, 2020

Privacy and Employee Issues During the New COVID-19 Pandemic Era

The global pandemic has created unique risks for handling employees’ exposure to, or positive testing for, COVID-19. To ensure a safe workplace, companies have to address delicate issues surrounding employee safety. The United States does not have a federal privacy law to address this specific situation (unlike Europe and Canada) and the treatment of employees personal information. Interestingly, the HIPAA laws do not cover employers...

General

6 May, 2020

Chipotle Mexican Grill Enters Three-Year DPA and Pays $25 Million Penalty for Food Safety Violations (Part II of II)

In the Chipotle Mexican Grill case, DOJ entered into a three-year deferred prosecution agreement (“DPA”) in exchange for the payment of a $25 million penalty stemming from a string of foodborne-illness cases between 2015 and 2018 involving its restaurants in which more than 1100 people became ill. The charges against Chipotle stem from outbreaks of norovirus, a highly infective pathogen that is easily transmitted by...

Featured Articles:

Unraveling Beneficial Ownership Risks (Part II of IV)

Addressing Beneficial Ownership Requirements in Your Compliance Program (Part I of IV)

Episode 142: Covid-19: The New Risk and Compliance Framework

In a Unanimous Decision, the Supreme Court Reverses New Jersey Bridgegate Convictions

Cancer Treatment Center Agrees to DPA and $100 Million Penalty for Criminal Antitrust Violations in Florida Market

Despite Pandemic, OFAC Settles with Animal Nutrition Company for $257k for Violations of Cuban Sanctions Program

Episode 141 — Practical Approaches to Managing Beneficial Ownership Risks (Part II of II)

Episode 140 — Addressing Beneficial Ownership Interest Risks in Your Compliance Program (Part I of II)

Privacy and Employee Issues During the New COVID-19 Pandemic Era

Chipotle Mexican Grill Enters Three-Year DPA and Pays $25 Million Penalty for Food Safety Violations (Part II of II)

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