Corruption, Crime & Compliance

Featured Articles:

10 Dec, 2019

Ericsson’s Pervasive Bribery Conduct: The Toxic Mix of Senior Executive Involvement and Third Party Corruption (Part II of II)

Ericsson’s FCPA settlement is in the books (not the books and records). But it casts a significant shadow across the FCPA landscape. A pervasive and systemic culture of bribery is defined to reflect senior executive involvement, winning business at any cost and using bribery as an accepted business strategy. Ericsson will now pay more than just the price of a $1 billion settlement; it will...

General

9 Dec, 2019

Ericsson Pays $1 Billion for Systemic FCPA Violations (Part I of II)

The Sweden-based telecommunications company, Ericsson, agreed to a pay a total of $1 billion (yes, billion with a “B”) for FCPA violations. Ericsson entered into settlement agreements with DOJ and the SEC. Ericsson agreed to pay a criminal penalty of over $520 million and approximately $540 million to the SEC. An Ericsson subsidiary in Egypt entered a guilty plea to an FCPA conspiracy to violate...

Podcasts

8 Dec, 2019

Episode 119 — The Ericsson FCPA Settlement

General

5 Dec, 2019

DOJ Indicts Former Braskem CEO on FCPA Criminal Charges

Recently, the Justice Department unsealed an indictment charging Jose Carlos Grubisich, the former CEO of Braskem S.A. with participating in an FCPA conspiracy with Odebrecht S.A. Grubisisch was arrested last Wednesday. Copy Here. Grubisich is charged with one count of conspiracy to violate the FCPA bribery provisions, one count of FCPA conspiracy to violate the FCPA’s books and records provisions and falsely certifying financial reports,...

General

4 Dec, 2019

Apollo Aviation Group Pays $210k to OFAC for Violations of Sudanese Sanctions Program

Apollo Aviation Group, now Carlyle Aviation Partners, agreed to pay OFAC $210,600 for 12 violations of the Sudanese Sanctions Program. Carlyle acquired Apollo in December 2018, and Carlyle was not involved in the transactions. The broad prohibition in the Sudanese Sanctions Program were lifted on January 17, 2017, but the transactions occurred prior to the relaxation of the sanctions program. Apollo was a multi-strategy aviation...

General

3 Dec, 2019

DOJ Tweaks FCPA Corporate Enforcement Policy

The Department of Justice recently announced updates to its Foreign Corrupt Practices Act Corporate Enforcement Policy. While the changes were relatively minor, the modifications underscored important principles surrounding the FCPA Corporate Enforcement Policy. There is no question that DOJ has landed on a Corporate Enforcement Policy that took years to develop. The FCPA Corporate Enforcement Policy now applies to all corporate criminal prosecutions except Antirust...

Events

2 Dec, 2019

Webinar: Third-Party Risk Management — Practical Solutions to Due Diligence, Monitoring and Testing

Wednesday, December 18, 2019 12 NOON EST Sign Up Here As more companies implement automated solutions to manage their third-parties, compliance officers face a growing list of new challenges to managing third-party risk. The Justice Department and the Department of Treasury (OFAC) have elevated the importance of managing anti-corruption and sanctions risks by issuing compliance program guidance. As part of this new set of expectations,...

General

2 Dec, 2019

Apple Pays $467K to OFAC for Sanctions Violations

Even the mighty can fall – Apple agreed to pay OFAC $467k for violations of the Foreign Narcotics Kingpin Sanctions regulations. In 2008, Apple entered into an applications development agreement with SIS, a Slovenian company. SIS and its director and majority owner, Savo Stjepanovic, were designated under the Foreign Narcotics Kingpin Designation Act and added to the Specially Designated Nationals List (“SDN List”). Apple’s screening...

Podcasts

1 Dec, 2019

Episode 118 — OFAC Enforcement Update and Lessons Learned

OFAC’s aggressive enforcement program continues. Recently, OFAC announced settlements with Apollo Aviation and Apple. Both of these cases underscore the importance of enhancing OFAC compliance programs. In this Episode, Michael Volkov reviews the two cases and the specific lessons learned.