Featured Articles:

J&F Investimentos Pleads Guilty to FCPA Bribery Conspiracy and Settles SEC Case for Total of $283 Million (Part I of V)

J&F Investmentos SA (“J&F), a Brazilian private investment company, plead guilty to FCPA bribery violations in federal court in Brooklyn, New York.  As part of the plea agreement, J&F agreed to pay a fine of $256 million and to cooperate with ongoing investigations of other companies and individuals involved in the bribery schemes. J& F owns numerous companies around the globe, including in the meat...

Episode 165 — Boeing Continues to Struggle from 737 MAX Safety Scandal

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. In this Episode, Michael Volkov reviews recent events surrounding Boeing’s 737 MAX scandal. The...

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...

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...

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...

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...

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...

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...

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...

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...