Corruption, Crime & Compliance

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10 Oct, 2023

DOJ Extends Voluntary Disclosure Benefits to Merger and Acquisitions

As part of its continuing effort to encourage corporate voluntary disclosures, the Department of Justice announced revised voluntary disclosure policies applicable to mergers and acquisitions. In a speech at the recent annual Society of Corporate Compliance and Ethics annual meeting in Chicago, Lisa Monaco, Deputy Attorney General, outlined the new voluntary disclosure policies. DAG Monaco described the importance of DOJ’s policy promoting corporate commitment to...

Podcasts

9 Oct, 2023

Episode 293 — Catching Up with California and State Data Privacy Laws

The United States continues to suffer from the absence of a federal data privacy and breach law. Congress has tried for years to broker a deal here but has never been able to overcome strong lobbying forces — whether its high-tech, trial lawyers, law enforcement or other gadflies, the public continues to suffer. Instead, global businesses face a real mess, tracking data privacy laws state-by-state,...

General

8 Oct, 2023

Compliance Week Sessions with Volkov Law – November 6th and 7th

Don’t miss our sessions! Volkov Law’s Michael Volkov, Steve Naughton, and Jessica Sanderson will be speaking at Compliance Week’s virtual “Third-Party Risk Management Oversight Summit” on November 6 and 7, 2023. Compliance Week is offering our followers a 15% discount (see code below). Mike and Steve will present together on Monday, November 6th, in an afternoon session entitled, “The ABCs of an Effective Third-Party Risk...

General

5 Oct, 2023

Clear Channel Settles SEC FCPA Case Against Former Chinese Subsidiary for $26.1 Million

The Securities and Exchange Commission continues to rack up FCPA enforcement actions. In its latest settlement, Clear Channel Outdoor Holdings agreed to pay $26.1 million for bribery violations committed by its former Chinese subsidiary. According to Clear Channel, the Department of Justice closed its FCPA investigation. Clear Channel, a San Antonio-based advertising company, paid bribes to Chinese government officials with cash, gift cards, first-class travel,...

General

4 Oct, 2023

Alex Cotoia Discusses Recent Anti-Boycott Enforcement Action on Passages: The International Trade Blog

Alex Cotoia, Regulatory Manager at The Volkov Law Group, recently appeared on David Noah’s podcast to review the Bureau of Industry and Security’s enforcement action against Pratt & Whitney for violation of the Anti-Boycott regulations. You can listen/watch the podcast HERE. Alex Cotoia’s blog post on the enforcement action is HERE.

General

4 Oct, 2023

Lessons Learned from the Albemarle FCPA Enforcement Action: Mind Your Third Parties (Part III of III)

The Albemarle FCPA enforcement action was announced at a good time. This year has been a slow year for DOJ’s FCPA enforcement program, although there are several months before the end of the year. The SEC, on the other hand, has been steady this year — the Albemarle and Clear Channel enforcement actions are numbers eight and nine for the year. The Albemarle enforcement action...

General

3 Oct, 2023

Albemarle’s Reliance on Third-Parties to Execute Bribery Schemes (Part II of III)

Albemarle’s bribery schemes look and sound like text-book examples of third-party agents being paid high commissions as a way to funnel bribery payments to foreign officials at state-owned oil refineries. However, as usual, there is more than meets the eye in the factual descriptions. The DOJ and SEC settlements focused on bribery conduct in Vietnam, Indonesia and India. However, the SEC also cited Albemarle’s control...

General

2 Oct, 2023

Albemarle Settles DOJ and SEC FCPA Cases for $218 Million (Part I of III)

Albemarle Corporation (Albemarle), a specialty chemicals manufacturing company located in Charlotte, North Carolina, agreed to pay more than $218 million to settle FCPA investigations with DOJ and the SEC stemming from bribery payments in Vietnam, Indonesia and India. Albemarle entered into a three-year non-prosecution agreement (“NPA”) with DOJ and agreed to pay a penalty of approximately $98.2 million and an administrative forfeiture of approximately $98.5...

Podcasts

2 Oct, 2023

Episode 292 — A Deep Dive into 3M’s SEC FCPA Settlement

The SEC is having a good year in prosecuting FCPA cases. The SEC’s recent settlement with 3M Corp. for $6.5 million is its seventh corporate resolution for the year. DOJ, which has been relatively quiet so far this year, recently resolved the Corficocolombiana case, its first for the year. 3M’s conduct centered on payments for Chinese healthcare officials employed by state-owned enterprises to attend overseas...

General

28 Sep, 2023

OFAC Imposes Modest $31,867 Penalty on Emigrant Bank for Iran Sanctions Violations, Highlighting Value of Voluntary Disclosure

Sam Finkelstein, Associate at The Volkov Law Group, rejoins us for another post on an OFAC enforcement action. Sam can be reached at [email protected]. Emigrant Bank (“Emigrant”), a U.S.-based financial institution that bills itself as the oldest bank in New York City, is the latest sanctions violator to be swept up in OFAC’s ongoing enforcement push. On September 21, OFAC announced that Emigrant agreed to...