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Episode 349 — The BIT Mining FCPA Settlement

Episode 349 — The BIT Mining FCPA Settlement

What happens when a Chief Executive Officer becomes the architect of a global bribery scheme? In this episode of Corruption, Crime, and Compliance, Michael Volkov delivers an in-depth analysis of the BIT Mining FCPA case — a landmark matter that underscores the severe consequences of C-suite misconduct. With CEO Zhengmin Pan at the center of the conspiracy, BIT Mining’s efforts to infiltrate Japan’s emerging casino...

BIT Mining FCPA Settlement and Lessons Learned (Part III of III)

BIT Mining FCPA Settlement and Lessons Learned (Part III of III)

Bit Mining, formerly 500.com, was a doomed company from the beginning,  When a CEO orchestrates a bribery scheme with the assistance of other senior executives, shareholders and the public have little chance of ensuring a business operating with ethics and integrity. 500.com’s future was sealed when it embraced bribery as a means to avoid head-to-head competition against established US and European companies seeking to enter...

BIT Mining Bribery Scheme — CEO Directed Payments and the Cover-Up (Part II of III)

BIT Mining Bribery Scheme — CEO Directed Payments and the Cover-Up (Part II of III)

In reviewing FCPA bribery fact patterns, it is a rare occasion when a company’s CEO is at the epicenter of the criminal conspiracy.  In the BIT Mining case, standing atop all of the actors is the CEO  Zhengming Pan, Bit Mining’s former CEO and a Chinese national. DOJ had no choice but to charge Pan with a criminal FCPA conspiracy. Others could have been charged...

BIT Mining CEO Indicted for FCPA Violations — Bit Mining Pays $10 Million to Settle DOJ and SEC FCPA Cases (Part I of III)

BIT Mining CEO Indicted for FCPA Violations — Bit Mining Pays $10 Million to Settle DOJ and SEC FCPA Cases (Part I of III)

Earlier this year, Bit Mining and its CEO fell under the FCPA hammer.  Bit Mining, formerly known as 500.com, resolved investigations with the Justice Department and the SEC for its corrupt scheme to bribe Japanese government officials.  On the same date, DOJ announced the indictment of Zhengming Pan, Bit Mining’s former CEO and a Chinese national, for FCPA violations.  BIT Mining entered into a three-year...

Episode 348 — Deep Dive into Telefónica DOJ Settlement for FCPA Violations

Episode 348 — Deep Dive into Telefónica DOJ Settlement for FCPA Violations

Telefónica Venezolana C.A. (“Telefónica Venezolana”), the Venezuela-based subsidiary of Telefónica S.A. (Telefónica), the Spanish telecommunications company entered into a deferred prosecution agreement (“DPA”) and agreed to pay over $85.2 million to resolve DOJ FCPA charges stemming from bribery payments to Venezuelan government officials to secure preferential access to U.S. dollars in a currency auction. Telefónica Venezolana entered into a three-year DPA and the filing of a...

Start the New Year with Two Important Webinars: 2024 FCPA Review (Jan. 7) & 2024 Sanctions Review (Jan. 14)

Start the New Year with Two Important Webinars: 2024 FCPA Review (Jan. 7) & 2024 Sanctions Review (Jan. 14)

2024 FCPA Year in Review January 7, 2024, 12 Noon EST SIGN UP HERE FCPA: For the Justice Department and the SEC, 2024 was an interesting year in FCPA enforcement and compliance. With the new Trump Administration taking over in 2025, DOJ’s commitment to FCPA enforcement may be questioned. This past year included several significant FCPA enforcement matters — Raytheon, Trafigura, Gunvor and SAP, along with...

OFAC Fines U.S. Person $1 Million for Multiple Violations of Sanctions Regime Against Iran

OFAC Fines U.S. Person $1 Million for Multiple Violations of Sanctions Regime Against Iran

In one of the more notable enforcement actions of 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) recently imposed a $1,104,408 civil penalty on a U.S. person for 75 separate violations of the Iranian Transactions and Sanctions Regulations (“ITSR”). The underlying violations, which occurred from 2019 to 2022, involved the purchase, renovation, and operation of a hotel on the Caspian...

American Life Insurance Company Settles with OFAC for $178,421 Related to Apparent Violations of Iranian Transactions and Sanctions Regulations

American Life Insurance Company Settles with OFAC for $178,421 Related to Apparent Violations of Iranian Transactions and Sanctions Regulations

By: Daniela Melendez, Associate at The Volkov Law Group, and Alex Cotoia, Regulatory Compliance Manager. Daniela can be reached at [email protected] and Alex can be reached out at [email protected]. The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) recently settled with American Life Insurance Company (“ALICO”), a Delaware-based subsidiary of MetLife, Inc., for $178,421, addressing apparent violations of the Iranian Transactions and Sanctions Regulations (“ITSR”)....

Antitrust Division AAG Outlines Need for More Aggressive Antitrust Enforcement in the Healthcare Industry

Antitrust Division AAG Outlines Need for More Aggressive Antitrust Enforcement in the Healthcare Industry

In an interesting political twist, the difference in approaches to antitrust enforcement between Democrat and Republican Administrations has been narrowing.  It used to be that the difference in party control of the Antitrust Division and the Federal Trade Commission would have a significant impact on enforcement priorities.  That gap is definitely changing and reflects growing agreement in the public in preventing anti-competitive conduct. Much of...

Episode 347 — LRN’s Code of Conduct Report

Episode 347 — LRN’s Code of Conduct Report

LRN consistently provides high-quality reports and important insights on ethics and compliance trends.  Each year, LRN’s Program Effectiveness Report is anticipated as an important source of cutting-edge ethics and compliance initiatives. LRN’s Code of Conduct Report includes a number of important benchmarks for companies to use as a measure of their compliance programs.  In its most recent report, LRN cites a number of important findings...