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Episode 202 — A Deep Dive into the Alfa Laval OFAC Enforcement Action

In two separate enforcement actions, OFAC announced settlements with Alfa Laval Middle East Ltd., a Dubai, UAE company (AL Middle East), and Alfa Laval, Inc., a Virginia-based company (AL US) for violations of OFAC’s Iran Sanctions Program. AL US enlisted its then subsidiary (now operating unit), Alfa Laval Tank, Inc, based in Exton, Pennsylvania (AL Tank), to participate in the scheme.  The Alfa Laval enforcement...

DOJ’s Criminal Cartel Prosecution of Chicken Industry Expands Net — Koch Foods and Four Pilgrim’s Pride Executives Charged

The Justice Department’s Antitrust Division continues to target a sprawling cartel investigation of the chicken industry.  In its most recent action, the Justice Department announced an indictment of Koch Foods and four individual executives from Pilgrim’s Pride tying them into the broad price-fixing conspiracy for the sale of broiler chicken products to the restaurant and retail industries. The expanding Justice Department investigation has charged 14...

A Basic Question — Where is the CCO’s Office?

Sometimes compliance issues are simple.  Most times they are nuanced.  This is a simple issue but it carries with it a significant message.  So here goes – where is the CCO’s office? To clarify rather than complicate, let’s take ourselves out of the remote workplace.  In the physical office, where is the CCO’s office located? I am a big fan of the movie Office Space...

Unraveling Trade Compliance Issues Involving China’s Human Rights Abuses in Xinjiang

Companies with supply chains stretching into China and Xinjiang are facing a mountain of compliance challenges.  Over the summer, the Biden Administration has taken numerous aggressive steps to pressure China to address human rights violations in the Chinese province of Xinjiang focusing on the repression of more than a million Uyghurs in that region. Those companies that maintain  supply chains anywhere in Xinjiang have to...

When a CCO Fails to Speak Up

We often discuss the importance of a “Speak Up” culture.  We encourage employees to report their concerns, we emphasize the important of such reporting to the life of an organization. Chief Compliance Officers are a key messenger to spread the message of speaking up.  But what happens when the CCO hesitates or even fails to speak up?  After we all take a little truth serum,...

Alfa Laval pays over $432K for Violations of OFAC’s Iran Sanctions Program

In two separate enforcement actions, OFAC announced settlements with Alfa Laval Middle East Ltd., a Dubai, UAE company (AL Middle East), and Alfa Laval, Inc., a Virginia-based company (AL US) for violations of OFAC’s Iran Sanctions Program. AL US enlisted its then subsidiary (now operating unit), Alfa Laval Tank, Inc, based in Exton, Pennsylvania (AL Tank), to participate in the scheme.  The Alfa Laval enforcement...

Company Kool-Aid, Misconduct and a Misfiring Corporate Culture

We all know (and repeat every day) that corporate cultures reflect social trends and pressures.  Companies face extraordinary political and social pressures, and this translates into its corporate workforce. Without being overly dramatic, we are witnessing a fundamental social decay in belief in our institutions.  This is not a recent phenomenon – it has accelerated over the last twenty years, and interestingly, has fluctuated over...

Why Do Companies Resist Change?

“Never doubt that a small group of thoughtful, committed, citizens can change the world. Indeed, it is the only thing that ever has.”― Margaret Mead Let’s start with a basic premise – change is a good thing (or the cynics insist, change may be a good thing).  But most people do not like change. Most people find change threatening, so they would rather know the devil...

Fixating on the Inextricable Link: Culture and Misconduct

Everyone is now on the culture bandwagon.  For those of us pushing the issue over the last decade, welcome aboard to everyone.  But once you join, the work is only beginning. Recent converts are embracing “culture assessments” as the new indicator of enlightenment.  That is a terrific development.  But there is more work to do. To reset the stage, we start with the basic proposition...

Looking Under the Hood – When Employees Engage in Wrongdoing?

The following scenario is disturbing and occurs all too often – a company receives a hotline report of misconduct occurring in its operations in a foreign country, India, for example.  The company launches an internal investigation of the matter and substantiates the allegation.  Financial misconduct occurred, discipline is imposed, two employees are fired and minor adjustments are made to India’s operations.  End of story, case...