Corruption, Crime & Compliance - Page 2 of 217

Featured Articles:

11 Mar, 2019

Russian Mobile Carrier, Mobile Telesystems, Settles FCPA Case with DOJ and FCPA for $850 Million; MTS Executive and Notorious Uzbek Government Official Indicted (Part I of III)

In another blockbuster FCPA prosecution, the Justice Department and the SEC announced an $850 million settlement with Mobile Telesystems (“MTS”), Russia’s largest mobile carrier. At the same time, the Justice Department announced criminal indictments against an MTS executive and the notorious corrupt Uzbek official, Gulnara Karimova, on criminal charges. MTS is the largest mobile telecommunications company in Russia, and has stock that is publicly-traded in...

Podcasts

10 Mar, 2019

Episode 80 — Best Practices for Investigation of Allegations of Sexual Misconduct in the #MeToo Era

The corporate governance landscape is littered with companies that have suffered major legal and reputational damage as a result of failure to promote and protect a safe workplace environment. Companies have failed to hold offenders accountable for sexual misconduct and violation of applicable legal and code requirements. The #MeToo era has resulted in increased reporting of sexual misconduct allegations and requires enhanced monitoring of corporate...

General

7 Mar, 2019

DOJ Sweeps Up Two More Defendants in PDVSA Criminal Investigation

The Justice Department’s sprawling and successful prosecution of bribery and money laundering surrounding PDVSA, Venezuela’s state-owned energy company, shows no signs of letting up. DOJ’s prosecutions began in 2015, and with the recent announcement of two new defendants, DOJ’s scorecard has reached a total of 21 defendants, 15 of whom have pleaded guilty. Given PDVSA’s reputation for corruption, which is well earned (or as I...

Events

7 Mar, 2019

Webinar: Best Practices for Internal Investigations of Sexual Misconduct Allegations in the #MeToo Era

Webinar: Best Practices for Investigation Sexual Misconduct Allegations in the #MeToo Era March 26, 2019, 12 Noon EST SIGN UP HERE The corporate governance landscape is littered with companies that have suffered major legal and reputational damage as a result of failure to promote and protect a safe workplace environment. Companies have failed to hold offenders accountable for sexual misconduct and violation of applicable legal...

General

6 Mar, 2019

OFAC Announces Yet Another Enforcement Action – Cement Clinker Company Settles for Violations of Iran Sanctions Program

OFAC is definitely off to a fast start this year – it recently announced its fourth enforcement action for 2019. So far, OFAC has collected over $7 million in civil penalties. While this may not appear to be a lot of money in civil penalties, it is important to remember the consequences of an OFAC settlement and scrutiny for future violations, restrictions on exports, and...

General

5 Mar, 2019

DOJ Arrests Micronesian Official and Hawaii-Based Businessman Pleads Guilty to FCPA Violation

In January 2019, the Justice Department brought an interesting FCPA prosecution involving a Hawaii-based businessman, Frank James Lyon, and Master Halbert, a government official from Micronesia. DOJ’s prosecution was interesting for two significant reasons – first, it was another example of DOJ enforcement efforts against the payor of the bribe for violating the FCPA and the recipient of the bribe, the foreign official, for money...

General

4 Mar, 2019

The Criminal Pursuit of Huawei China: DOJ Brings Two Indictments

The Department of Justice has launched two separate criminal cases against Huawei China, the controversial Chinese telecommunications equipment provider. For years, US government officials have questioned the ownership, control and practices of Huawei, claiming that it is owned by the Chinese government and acting as an agent for Chinese interests. At the end of January, the Justice Department announced two separate indictments against Huawei, and...

General

27 Feb, 2019

AppliChem Pays OFAC $5.5 Million for Cuba Sanctions Violations

OFAC continues to pile up enforcement actions for sanctions violations. In yet another example of a failure of companies to address compliance, to follow up on compliance and to ensure ultimate compliance, AppliChem, a German company agreed to pay $5.5 million for 304 violations of the Cuban Assets Control Regulations during the time period between May 2012 and February 2016. Specifically, AppliChem engaged in 304...

General

27 Feb, 2019

CCO and CLO “Authority”: A Fundamental Requirement

A basic compliance program control, which is often overlooked (or assumed to exist), is the requirement that a chief compliance officer and/or chief legal officer have the authority to stop a specific contract or business transaction. To simplify this statement, compliance and legal have to approve certain business transactions before they can proceed. If a compliance officer or legal officer is consulted just for “advice,”...