Corruption, Crime & Compliance

Featured Articles:

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...

General

5 May, 2020

DOJ Resolves Two Important Food Safety Criminal Cases: Blue Bell Creameries and Chipotle Mexican Grill (Part I of II)

In an important set of criminal prosecutions for food safety violations, the Justice Department recently announced resolutions with Blue Bell Creameries and Chipotle Mexican Grill. While these cases were not related to the COVID-19 pandemic, they are indications of DOJ’s aggressive prosecution for food safety issues and are important reminders of the need for organizations to prioritize health and safety issues. Corporate boards and senior...

General

4 May, 2020

DOJ and FBI Fight Back Against Pandemic Fraud

You can always count on cyber-criminals and fraudsters to come out of the woodwork when a national crisis occurs. The COVID-19 pandemic has resulted in a multitude of criminal schemes. Companies that rely on remote employees have to be vigilant in alerting employees to phishing, malware and other scams used by cyber-criminals and fraudsters. DOJ, the FBI and the private sector have been cooperating to...

Podcasts

3 May, 2020

Episode 139 — DOJ Resolves Two Food Safety Criminal Cases: Blue Bell Creameries and Chipotle Mexican Grills

The Justice Department recently resolved two food safety criminal cases involving Blue Bell Ice Cream and Chipotle Mexican Grills. In its largest food safety recovery to date, Chipotle agreed to a three-year deferred prosecution agreement and paid $25 million. In the Blue Bell Ice Cream case, Blue Bell agreed to plead guilty and pay $19.5 million in fines and penalties. Blue Bell’s former CEO, Paul...

General

30 Apr, 2020

Ensuring Employee Reporting in the New COVID-19 Pandemic Era

If there ever was a time that companies need to promote and encourage employee reporting, the time is now. By employee reporting, I do not mean to single out hotline reporting – certainly that is one of many avenues to report concerns. In this era of fear and worry, companies need to recognize that their respective workforces are suffering from trauma (possible loss of family...

General

29 Apr, 2020

The Importance of the Human Resources and Compliance Partnership in the New COVID-19 Pandemic Era

Human Resources and Compliance have always had a natural and tight bond, assuming that there is no territorial or in-fighting political disputes. In this new COVID-19 pandemic era, the HR and Compliance partnership is even more important. HR and Compliance have a critical challenge for moving forward – restoring employee trust in a safe and healthy work environment. Company workforces are shell-shocked and they need...

Featured Articles:

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)

DOJ Resolves Two Important Food Safety Criminal Cases: Blue Bell Creameries and Chipotle Mexican Grill (Part I of II)

DOJ and FBI Fight Back Against Pandemic Fraud

Episode 139 — DOJ Resolves Two Food Safety Criminal Cases: Blue Bell Creameries and Chipotle Mexican Grills

Ensuring Employee Reporting in the New COVID-19 Pandemic Era

The Importance of the Human Resources and Compliance Partnership in the New COVID-19 Pandemic Era

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