If you speak to members of a corporate board and the C-Suite and you ask them if the company has a strong ethical culture, we all know what they will say – “Of course, we do. We have a strong commitment to our Code of Conduct and Doing the Right Thing . . . . [blah blah blah].” You can listen, nod your head and...
In two recent FCPA enforcement actions, the Justice Department focused on bribery schemes involving Petroecuador government officials. Petroecuador is the state-owned oil and gas company in Ecuador. In the first, DOJ announced an indictment against Javier Aguilar, an oil trader at Vitol, an energy and commodity trading company, for his role in a five-year international bribery and money laundering scheme carried out in Ecuador. In the...
NAVEX Global has announced its upcoming virtual ethics and compliance conference. ( Formerly the Ethics & Compliance Virtual Conference (ECVC)). NAVEX’s upcoming conference theme is: Beyond the Moment. Sign Up HERE. NAVEX Global’s annual virtual conference is a terrific opportunity to catch up with the latest ethics and compliance trends and stay proactive in the field. NAVEX Global’s goal this year is to help everyone be...
Boeing’s culture and safety performance continues to undermine its ability to move forward and regain trust from regulators, the aviation industry and the flying public. Boeing has to undergo transformative change. All indications of reform are sparse and Boeing appears to be moving slowly but not so effectively to implement real and substantial reforms. Boeing faces significant challenges to the core of its culture and...
Boeing is the new poster child for corporate governance failures and misconduct. Move over Wells Fargo, General Motors, Volkswagen, Novartis, Siemens and Wal-Mart, and make room for Boeing. Like General Motors and its ignition switch scandal, innocent consumers were killed as a direct result of corporate governance failures and blatant misconduct. Boeing’s 737 MAX was rolled off the factory floor with fanfare and great expectations...
OFAC is a steady enforcement agency. As the COVID-19 pandemic settled down, OFAC resumed aggressive enforcement of economic sanctions. In its latest action, OFAC announced a settlement with Keysight Technologies (“Keysight”), a Santa Rosa, California, for conduct stemming from its former subsidiary, Anite Finland (“Anite”) for re-exports of US export-controlled test measurement equipment to Iran. In a familiar fact pattern surrounding OFAC compliance and acquisitions,...
The Justice Department announced a guilty plea to FCPA charges by Sargeant Marine, Inc., a privately-owned company, based in Boca Raton, Florida. Sargeant Marine, an asphalt company, plead guilty to one count of conspiracy to violate the anti-bribery provisions of the FCPA and agreed to pay a fine of $16.6 million for bribery schemes in Brazil, Venezuela and Ecuador. Between 2010 and 2018, Sargeant Marine...
Webinar: 2020 FCPA Enforcement and Compliance Review October 13, 2020, 12 Noon EST Sign Up HERE Despite the pandemic and disruptions to the global economy, the Justice Department and the Securities and Exchange Commission have resumed their aggressive enforcement of the FCPA. DOJ has continued its pace of corporate prosecutions while continuing to increase individual criminal prosecutions. DOJ and the SEC also issued a revised...
A federal grand jury in the Eastern District of New York returned an indictment against Javier Aguilar, an oil trader at Vitol, an energy and commodity trading company, for his role in a five-year international bribery and money laundering scheme carried out in Ecuador. Between approximately 2015 and July 2020, Aguilar and others participated in a conspiracy to pay and conceal bribes to Ecuadoran government...
Global companies have to conduct periodic audits of its high-risk third party partners. With the continuing pandemic, such audits have to be conducted remotely. As a result, companies face significant challenges in conducting these audits in these difficult times. In this Episode, Michael Volkov interviews Jessica Sanderson, Partner at The Volkov Law Group, on how to conduct a remote third party audit. LISTEN HERE
