Featured Articles:

Department of Justice’s Antitrust Division Sues Google (Again) for Monopolization of the Digital Advertising Market

In a significant action, DOJ’s Antitrust Division filed a complex complaint against Google charging it with a long-time scheme over 15 years to monopolize the digital advertising market. DOJ was joined by Attorneys General of California, Colorado, Connecticut, New Jersey, New York, Rhode Island, Tennessee, and Virginia. DOJ filed a separate antitrust case in 2020 against Google for monopolizing search and search advertising, which are...

Former Special Agent in Charge of the FBI New York Counterintelligence Division Charged with Violating Russia Sanctions

In an ironic twist (or you just can’t make this up moment, whichever you prefer), the Justice Department announced the arrest of Charles McGonigal, the former Special Agent in Charge (“SAC”) of the FBI’s Counterintelligence Division in New York, along with Sergey Shestakov, a former Russian diplomat, in a five-count indictment for violating Russian sanctions and money laundering laws.  The charges stem from services provided...

Justice Department Tweaks Corporate Enforcement Policy to Entice More Corporate Voluntary Disclosures

The Department of Justice announced revisions to its Corporate Enforcement Policy (“CEP”) yet again in order to promote voluntary disclosures by Companies that discover potential wrongdoing.  DOJ’s latest action demonstrated its commitment to several ideas: (1) Increasing prosecution of individual wrongdoers; (2) Offering benefits to companies to encourage self-reporting, cooperation and remediation; (3) Reducing the burdens on corporate shareholders from large fines and penalties that...

Episode 259 — Deep Dive into the Honeywell FCPA Case

Honeywell UOP (“Honeywell”) is a U.S.-based subsidiary of Honeywell International, Inc.  The settlement resolved bribery charges in the United States and Brazil stemming from bribes paid to high-ranking officials at Petrobras, Brazil’s state-owned oil company. Honeywell agreed to a three-year deferred purchase agreement (“DPA”), which was filed in the Southern District of Texas (Houston).  Honeywell agreed to pay approximately $79 million in exchange for the...

Webinar: Lessons Learned from 2022: Improving Your Ethics and Compliance Program

February 14, 2023 12 Noon EST Sign Up HERE The past year was a big year in ethics and compliance programs. Global companies face aggressive enforcement risks, including anti-corruption, sanctions, export controls, and antitrust. Adding to this situation, DOJ issued a new Corporate Enforcement Policy, which includes new and significant compliance program expectations. Chief compliance officers face heightened challenges and expectations from internal and external...

Next Steps for CCOs – Revising Compensation Systems and Enhancing Data Preservation Technology

Just when we thought the ethics and compliance landscape was “stable,” the Justice Department pulled the compliance profession further and announced heightened expectations for corporate compliance programs.  For prognosticators like myself it is easy to predict that next year companies will have to focus on their compensations systems and data preservation capabilities. DOJ has promised to issue additional guidance on these two important issues.  However,...

Bitzlato Cryptocurrency Exchange Founder Charged with Processing $700 Million in Illicit Funds

Matt Stankiewicz from The Volkov Law Group rejoins us for a posting on the recent Bitzlato, cryptocurrency scandal. Matt can be reached at [email protected]. On Wednesday, January 18, 2013, the U.S. Department of Justice (“DOJ”) unsealed a criminal complaint in the Eastern District of New York charging Russian-national Anatoly Legkodymov, a senior executive at Bitzlato Ltd. (“Bitzlato”), a cryptocurrency exchange registered in Hong Kong.  Legkodymov—also...

DOJ & OFAC Sanctions Predictions for 2023

Trade compliance is the new hot field.  Companies are catching up with trade compliance in response to the global sanctions regimes put in place to cripple Russia.  The United States, its allies and partners have implemented an unprecedented and complex set of sanctions and export controls.  Global businesses were tested.  Trade compliance became the center of attention and risks. In recognition of this reality, the...

Episode 258 — Deep Dive in the ABB FCPA Case

The Justice Department’s new Corporate Enforcement Policy and the heightened enforcement and compliance expectations were put to the test in its announcement of a $315 million settlement of bribery charges with ABB, a three-time loser in foreign bribery enforcement.  However you interpret this case, the ABB enforcement action demonstrates yet again the vitality of DOJ’s commitment to FCPA enforcement, and that the industry can expect...

OFAC’s New Year’s Eve Settlement with Danfoss for $4.3 Million for Sanctions Violations

OFAC closed out 2022 with a late-night $4.3 million settlement with Danfoss A/S, a Danish manufacturer of refrigeration and cooling products for violations of the Iran, Syria and Sudan sanctions programs.  OFAC has had a productive year – implementing and enforcing Russian sanctions while continuing its aggressive sanctions enforcement program.  For 2022, OFAC had 16 settlements along with $42 million in penalties.  Danfoss’ violations involved...