When a scandal hits the media like the Panama Papers leak of 11.5 million confidential legal records, we all know what to expect. Criminal investigations, regulatory responses, and of course, congressional hearings of some sort so that everyone gets a piece of the scandal pie. The International Consortium of Investigative Journalists (“ICIJ”) reported the leak of 11.5 million confidential legal records designed to expose shell...

Since 2010, the Justice Department and the SEC have been “investigating” a number of private equity and hedge funds for FCPA violations. The launch of the inquiries was a big deal with lots of fanfare and focus on private equity corruption risks. In time, nothing happened. Well, that is about to change. DOJ and the SEC are getting close to announcing a large settlement with...

You don’t need a weatherman to know which way the wind blows. – Bob Dylan, Subterranean Homesick Blues Political winds are important for a number of reasons. When working in the government, you have to seize the political opportunities to advance practical proposals. When it comes to requiring banks and financial institutions to collect beneficial ownership information from account holders and customers, the Panama Papers...

Let’s start with a big “If.” I know that sounds like a real turn off but bear with me. Assuming that the Justice Department is ready to turn over a new approach to criminal enforcement and aggressively prosecute culpable individuals in white collar crime investigations, would it be a good idea to offer a pass, or leniency to the company if the company self-reports the...

Just to add to the cacophony of voices campaigning during this primary season, DOJ, SEC, FINRA, and CFTC officials launched their own campaign promoting recent initiatives to increase corporate self-reporting of potential violations. After months of announcements, which were preceded by internal wrangling and bureaucratic leaks, DOJ has put in place its new initiative – the Yates memorandum to focus on individual culpability and a...

I am excited to announce a new sponsor of Corruption Crime and Compliance, Bureau van Dijk (BvD). I have been impressed with BvD’s product offering – key tools in your third party screening process that offer difficult to find information. BvD specializes in information on private companies, detailing company hierarchies and standardized financial reports so you can compare companies across international borders. BvD’s product range...

Job: Compliance Manager (Columbus, Ohio, metro area) A leading industrial growth company that delivers a comprehensive set of products for use in the construction and infrastructure sectors is seeking a Compliance Manager to oversee the day-to-day operation of its compliance program and internal controls procedures.  This position is suited for a self-motivated individual seeking to help structure and manage a program from the ground up. ...

There is something a little surreal when a CCO, while negotiating to join a company, raises the issue of his or her own termination. Not to be maudlin, but it is an important issue to consider. The dangerous scenario is not so far-fetched. A CEO or someone from the C-Suite pushes to terminate a CCO because a CCO is likely to uncover some potentially improper...

Lauren Connell, Managing Associate at The Volkov Law Group, joins us again for a posting on DOJ’s recent FCPA guidance announcement.  Lauren can be reached at [email protected].  Her bio is here.   Lots of people are talking about the DOJ’s new self-disclosure pilot program, but it was only the last of three steps announced in the DOJ’s Fraud Section FCPA Enforcement Plan and Guidance. One...