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General

30 Mar, 2023

Carrie Tolstedt, former Wells Fargo Community Banking Head, Agrees to Plead Guilty and Pay a $17 Million Fine for Obstruction of Regulator’s Investigation

If there ever is an example of a rotten corporate culture, Wells Fargo sits at the head of the class.  Since Wells Fargo’s sales pressure scandal, Wells Fargo has continued to suffer from a string of scandals and misconduct.  Along the way, and notwithstanding spending millions on lawyers, consultants, accountants and other professionals to fix its culture and controls, Wells Fargo still has not recovered. ...

General

29 Mar, 2023

Rio Tinto Pays $15 Million to Resolve FCPA Violations in Guinea

Rio Tinto, the global mining and metals company, agreed to pay the SEC $15 million to settle FCPA violations arising from an alleged bribery scheme involving a senior Guinean government official. Between 1997 and 2006, Rio Tinto was granted mining and exploration rights to four section blocks in the Simandou mountain region.  In late 2008, after a change in administrations, the Guinea Government revoked Raio...

General

28 Mar, 2023

Flutter Entertainment Settles SEC FCPA Case for $4 Million for Improper Payments to Russian Consultants

Flutter Entertainment, the previous owner of PokerStars, agreed to pay the Securities and Exchange Commission $4 million for improper payments to Russian-based consultants, stemming from conduct committed by The Stars Group, PokerStars previous owner.  Flutter purchased PokerStars in 2020. Flutter is an Ireland-based global gaming and sports betting company. Flutter was tagged with the FCPA violations committed by the Stars Group prior to Flutter’s acquisition. ...

Podcasts

27 Mar, 2023

Episode 267 — DOJ Escalates Compliance Program Requirements

The Justice Department is rapidly pushing corporations to a new level of compliance.  We are witnessing a watershed moment – DOJ is raising the bar on expectations surrounding corporate compliance programs.  It would be a mistake, however, to interpret DOJ’s recent changes as limited to compliance compensation and preservation  of internal communications data. When considered together, the changes to the Corporate Enforcement Policy, the Evaluation...

General

26 Mar, 2023

Alex Cotoia Featured on Tom Fox’s Diligent Third-Party Risk Management Podcast Series

Alex Cotoia, Regulatory Manager at The Volkov Law Group, recently was featured on Tom Fox’s Diligent Podcast Series focused on Third-Party Risk Management. The Podcast is available HERE. In 2022, the overwhelming majority of FCPA related enforcement actions involved third parties and required organizations to reprioritize third party risk management. In this episode, Alex and Tom consider case studies involving ABB Limited, GOL Airlines and...

General

24 Mar, 2023

Michael Volkov on SCCE Podcast: What We Learned in 2022 and What it Means for 2023

I was honored to appear on Adam Turteltaub’s Society of Corporate Compliance and Ethics (SCCE’s) Podcast to discuss significant compliance events in 2022 and trends for 2023. Adam’s Introduction: A lot happened in compliance in 2022, with a large number of lessons for 2023. To sort it out we turned to Michael Volkov, of the Volkov Law Group and host of the Corruption, Crime & Compliance blog and podcast....

General

22 Mar, 2023

Corsa Coal Earns Declination and Agreed to Disgorge $1.2 Million

The Justice Department has been pushing its voluntary self-disclosure program and changes to its Corporate Enforcement Policy, in an attempt to increase FCPA enforcement cooperation.  The Golden Ring for every company facing this situation is a declination with disgorgement.  Only 17 companies have achieved that result. The latest beneficiary is Corsa Coal Corporation (“Corsa”), which cooperated with the Justice Department and resulted in the successful...

General

21 Mar, 2023

DOJ Outlines Compliance Expectations Relating to Preservation of Data from Messaging Applications (Part III of III)

The Justice Department finally released its new policy to improve corporate preservation of data generated by executives and employees.  In this new technology era, companies have had significant gaps in collecting and reviewing data generated by messaging applications, texting systems and emails.  While many employees have been using personal devices for business purposes, a large number of companies have failed to apply strict BYOD policies...

General

20 Mar, 2023

DOJ’s Criminal Division Issues Three-Year Pilot Program for Corporate Compensation Systems and Clawbacks (Part II of III)

The Justice Department is focusing with a laser beam on corporate incentives and disincentives.  This truly is a remarkable initiative and companies should undertake their own holistic review of internal incentives and disincentives.  For years, we have heard about corporate incentives to achieve earnings and how sales rewards can unintentionally distort compliance.  As an important step, DOJ’s Criminal Division recently issued its new, three-year Pilot...

Podcasts

20 Mar, 2023

Episode 266 — Joint Compliance Notice Issued on Sanctions and Export Controls Evasion

As we have noted on numerous occasions, the U.S. Russia Sanctions and Export Control Program is unprecedented and a compliance challenge for all organizations.   In another unprecedented action, the Justice Department and the Departments of Commerce and Treasury issued a Joint Compliance Note (“JCN”) on the importance of compliance with the Russia Sanctions and Export Control requirement, which provides important descriptions of red flags and...

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