Corruption, Crime & Compliance

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17 Oct, 2020

Corruption Crime & Compliance: Subscribe to Blog and Podcast

Corruption, Crime & Compliance offers both blog postings and fresh podcasts on important legal and compliance topics. To make your life a little easier, we offer a subscription service so that you receive convenient notices of new blog postings and podcast episodes. Here are the subscription links: Apple Podcasts | Android | Email | Google Podcasts | Stitcher | Corruption, Crime & Compliance also maintains an email subscription feature. You can sign up on...

General

15 Oct, 2020

DOJ Indicts Former CEO of Cancer Treatment Company for Conspiracy

The Justice Department’s Antitrust Division’s criminal enforcement program is having a strong year. Since completing its long-term and record-setting prosecution of Japanese auto parts suppliers, the Antitrust Division focused attention on new industries, including generic pharmaceuticals, chicken processors, government contractors, electronic capacitors, and health care. It takes time to bring about results. This year, the Antitrust Division, along with state prosecutors, focused on the Florida...

General

14 Oct, 2020

Letting Third Parties Do the Dirty Work

We all know it when we see it – a recurring fact pattern in which a company enlists a corrupt third party intermediary for one purpose (and one purpose only) – to pay a bribe. Let me give you a few examples. Cognizant Technology In the Cognizant Technology FCPA enforcement action, the former President and General Counsel directed the scheme with two other C-Suite officers...

General

13 Oct, 2020

DOJ Adds Six New Defendants to Price-Fixing Boiler Chicken Conspiracy

The Justice Department announced a major expansion of its ongoing investigation and prosecution of executives and employees in the boiler chicken price-fixing conspiracy. DOJ recently returned a superseding indictment adding six new defendants to the boiler chicken conspiracy indictment, and expanding the scope of the charged conspiracy. (Here for earlier Posting on conspiracy). The new indictment charges ten (10) executives and employees at boiler chicken...

General

12 Oct, 2020

RNC Deputy Finance Chair Elliott Broidy to Plead Guilty to Foreign Agent Registration Act Conspiracy

The former deputy finance chair of the Republican National Committee and prominent fundraiser for President Trump has agreed to plead guilty with lobbying on behalf of Jho Low, an indicted and fugitive financier, who was charged in the ongoing 1MDB sovereign wealth fund investigation and prosecution. Broidy agreed to assist Jho Low by lobbying the Justice Department and administration and failed to register as required...

Podcasts

11 Oct, 2020

Episode 164 — Catching Up on Recent OFAC Enforcement Actions

OFAC has resumed its aggressive enforcement program. These enforcement actions include: (1) Keysight Technologies settled with OFAC for $473,157 for violations of the Iran Sanctions Program; (2) Comtech Telecommunications settled with OFAC for $894,111 for violations of Sudan Sanctions Program; and (3) Deutsche Bank settles two OFAC cases totaling $583K for violations of Ukraine-Russia Sanctions Program. In this Episode, Michael Volkov discusses these three separate enforcement actions. The...

General

9 Oct, 2020

Welcome to New Sponsor: Blue Umbrella

We are proud to announce the addition of a new sponsor — Blue Umbrella, a leading provider of due diligence research and innovative third-party compliance technologies. Combining global research excellence with disruptive RegTech SaaS solutions, Blue Umbrella serves multinational corporations working in technology, manufacturing, life sciences, defense/aerospace, agriculture, energy, finance, and consumer goods as well as top-tier investment banks. With a global presence and local...

General

8 Oct, 2020

SEC Amends Whistleblower Rules

By any measure, the SEC’s whistleblower program has been a success. Since its inception about 10 years ago, the SEC has collected $2.5 billion in financial recoveries based on whistleblower tips. A large portion of this money has been returned to victim investors. Section 922 of the Dodd-Frank Wall Street Reform and Consumer Protection Act added Section 21F to the Securities Exchange Act of 1934...

General

7 Oct, 2020

OFAC Settles with Generali Global Assistance, Inc. for $5.8 Million for Violations of Cuban Sanctions

OFAC continues to chalk up enforcement actions. For the year, even with the pandemic slow down, OFAC has reached 13 settlement agreements totaling $18.6 million in penalties. In its latest enforcement settlement, Generali Global Assistance, Inc. (“GGA”), a US-based travel assistance services company that provides travel and claims services on behalf of clients that offer global medical expense and travel insurance policies, agreed to pay...

General

5 Oct, 2020

DOJ, CFTC and SEC Settle Spoofing Fraud Charges with JP Morgan for $920 Million

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...