Featured Articles:

General

4 Oct, 2022

DOJ Charges Russian Oligarch Oleg Deripaska and Three Associates for Sanctions Evasion and Obstruction of Justice

In a significant action, the Justice Department brought criminal charges against the notorious Russian Oligarch, Oleg Deripaska, for sanctions evasion and obstruction of justice.  DOJ also charged three associates, Natalya Bardakova, a Russian citizen, Olga Shriki, a New Jersey resident and United States citizen, and Ekaterina Voronina, Deripaska’s girlfriend.  Shriki is also charged with obstruction of justice for deleting various electronic records after she received...

General

3 Oct, 2022

Oracle’s FCPA Violations: A Lesson in Managing Third-Party Distributor Risks (Part II of II)

Oracle’s SEC settlement for $23 million underscores the power of the FCPA provisions mandating effective internal controls and accurate books and records.  As everyone knows, these provisions can be applied to a wide-range of conduct beyond foreign bribery.  The SEC recognizes the power of these provisions and have used them in a variety of settings. Oracle has now fallen under the enforcement sword twice —...

General

3 Oct, 2022

Oracle Joins Ranks of FCPA Recidivists: Settles SEC Case for $23 Million (Part I of II)

Oracle Corporation settled its second FCPA case in ten years.  Oracle agreed to pay $23 million to resolve allegations that its subsidiaries in Turkey, India and the United Arab Emirates maintained slush funds to bribe foreign officials.  Ten years ago in 2012, Oracle paid the SEC $2 million creating millions of dollars in off-the-books accounts at its India subsidiary. Oracle agreed to pay $8 million...

Podcasts

2 Oct, 2022

Episode 249 — DOJ Issues New Corporate Enforcement Policy

The Biden Administration promised a new, aggressive approach to corporate crime. Well, the Justice Department just delivered a new, comprehensive policy that raises a number of issues, some of which are likely to be controversial. The new policy incorporates reforms announced last October that largely centered on prior corporate criminal and civil records; appointment of independent compliance monitors and expanding review of responsible persons in an internal...

General

30 Sep, 2022

Criminal Division AAG Polite Reinforces New DOJ Corporate Enforcement Policy (Part IV of IV)

The Justice Department is putting every business on notice — aggressive white collar criminal enforcement is here to stay. In a one-two punch, Deputy Attorney General Lisa Monaco announced a revised Corporate Enforcement Policy, and Criminal Division Assistant Attorney General Kenneth Polite followed up with a speech outlining the steps the Criminal Division intends to take to implement the new Corporate Enforcement Policy, including important...

General

29 Sep, 2022

DOJ’s Revised Corporate Enforcement Policy Expands on Previous Factors: History of Misconduct; Voluntary Self-Disclosure; and Compliance Monitors (Part III of IV)

The Lisa Monaco Memo is a new and important restatement of the Justice Department’s approach to corporate crime.  It is a worthy read and it sets out a number of new requirements and procedures for DOJ prosecutors investigating corporate crime.  In this posting, we return to review a few remaining important issues. Evaluating a Corporation’s History of Misconduct — DOJ’s original announcement in October 2021...

General

27 Sep, 2022

DOJ Imposes New Standards for Evaluation of Corporate Compliance Programs: Compensations Structures that Promote Compliance (Part II of IV)

The Monaco Memo is a watershed moment as part of DOJ’s evolution and advocacy for effective ethics and compliance programs.  We have seen prior moments of significant action — DOJ’s adoption of the FCPA Guidance, DOJ’s issuance of its Evaluation of Corporate Compliance Programs, and now the Monaco Memo which takes compliance into a new world with new opportunities and challenges. The Monaco Memo starts...

General

26 Sep, 2022

DOJ Issues Sweeping New Corporate Criminal Enforcement Policy — A New Era of Compliance Begins with Increased Focus on Compensation and Incentives (Part I of IV)

The Biden Administration promised a new, aggressive approach to corporate crime.  Well, the Justice Department just delivered a new, comprehensive policy that raises a number of issues, some of which are likely to be controversial.  The new policy incorporates reforms announced last October that largely centered on prior corporate criminal and civil records; appointment of independent compliance monitors and expanding review of responsible persons in...

Events

26 Sep, 2022

Webinar: DOJ’s New Corporate Enforcement Policy — Taking Compliance to the Next Level

Webinar: DOJ’s New Corporate Enforcement Policy — Taking Complaince to the Next Level October 25, 2022 12 Noon EST SIGN UP HERE The Biden Department of Justice promised a tough, new approach to white collar enforcement. In a series of steps, the Justice Department has set out a new and comprehensive approach to corporate criminal enforcement with a direct and immediate impact across the Justice...

Podcasts

25 Sep, 2022

Episode 248 — Deep Dive into the GOL Brazil FCPA Enforcement Action

The Department of Justice and the Securities and Exchange Commission reached a $41 million settlement with GOL Linhas Aéreas Inteligentes S.A. (“GOL”) to resolve criminal and civil foreign bribery charges. GOL entered into a three-year deferred prosecution agreement (“DPA”) with DOJ in exchange for payment of a $17 million criminal penalty. DOJ credited $1.7 million of that penalty against a $3.4 million fine that GOL agreed...

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