Corruption, Crime & Compliance

Featured Articles:

16 Nov, 2021

Important Planning and Design Steps in Targeted Employee Survey Program (Part II of II)

A targeted employee survey program requires careful planning and communications prior to launching the survey program. Employee engagement in response to a specific survey requires transparent and robust explanations and assurances. In the absence of appropriate communications and assurances, employee response rates may decline. Employees have to understand why the survey is being conducted, whether anonymity will be protected, and how the results will be...

Monitoring and Measuring A Company’s Ethical Culture: Relevant Survey Strategies (Part I of II)

General

15 Nov, 2021

Monitoring and Measuring A Company’s Ethical Culture: Relevant Survey Strategies (Part I of II)

Chief compliance officers play a key role in managing a company’s ethical culture. Most companies fail to pay proper attention to its culture because it is difficult to define, measure and monitor. Such an approach is short-sighted. CCOs have to embrace this issue and develop appropriate techniques to measure a company’s culture. All too often I observe companies that rely on annual or semi-annual company-wide...

Podcasts

13 Nov, 2021

Episode 214 — Review of the Credit Suisse Global Fraud and Bribery Enforcement Action

Credit Suisse Group AG (“Credit Suisse”), a global financial institution, and its London-based European subsidiary, Credit Suisse Securities (Europe) Limited (“CSSEL”) resolved a wide-ranging bribery and fraud scheme involving investments and financing arrangements for an $850 million loan for a tuna fishing project in Mozambique. To resolve the violations, Credit Suisse agreed to pay a total of $547 million in penalties, fines and disgorgement as...

What to Know About the DOJ’s National Cryptocurrency Enforcement Team

General

12 Nov, 2021

What to Know About the DOJ’s National Cryptocurrency Enforcement Team

Matt Stankiewicz, Partner at The Volkov Law Group, rejoins us to discuss the DOJ’s cryptocurrency enforcement efforts. He can be reached at [email protected]. In early October, U.S. Department of Justice (“DOJ”) Deputy Attorney General Lisa Monaco announced the creation of the National Cryptocurrency Enforcement Team (“NCET”). The NCET will handle the Department’s investigations and enforcement actions relating to cryptocurrency and virtual assets, which has seen...

US Defense Contractor CEO Charged with Bribery

General

11 Nov, 2021

US Defense Contractor CEO Charged with Bribery

Bribery occurs in the United States — what a surprise! Transparency International’s Corruption Perception Index ranks the United States as 25 out of 179, a relatively low ranking for corruption. Some have argued (including me) that the US ranking may be inaccurate given current regulations surrounding campaign finance and other means by which influence peddling and corruption can occur with low detection risks. That is...

Rockwell Automation Executives Arrested for Fraudulent Scheme

General

10 Nov, 2021

Rockwell Automation Executives Arrested for Fraudulent Scheme

Little problems can become big ones. A failure to respond to a risk – whether it is a conflict of interest violation or a weakness in internal controls – can become even more significant depending on the size and scope of the problem. A recent criminal prosecution of two Rockwell Automation executives underscored the nature of this phenomena. Last month, federal prosecutors arrested and charged...

Deputy AG Lisa Monaco Suggests Major Changes to the DOJ’s Corporate Enforcement Efforts

General

9 Nov, 2021

Deputy AG Lisa Monaco Suggests Major Changes to the DOJ’s Corporate Enforcement Efforts

Alex Cotoia, Regulatory Manager at The Volkov Law Group, rejoins us for a post providing additional color into U.S. Deputy Attorney General Lisa Monaco’s recent announcement on changes to DOJ policies. Alex can be reached at [email protected]. On October 28, 2021, U.S. Deputy Attorney General Lisa O. Monaco—a veteran of government service in previous Administrations and a champion of corporate accountability—announced several significant changes to...

Justice Department Files to Block Penguin Random House’s Acquisition of Simon and Schuster

General

8 Nov, 2021

Justice Department Files to Block Penguin Random House’s Acquisition of Simon and Schuster

The Justice Department filed a complaint in the US District Court for the District of Columbia to block Penguin Random House’s acquisition of Simon & Schuster. Penguin Random House is the largest book publisher in the world and Simon & Shuster is the fourth largest publisher. Penguin Random House is a subsidiary of Bertelsmann SE and is based in New York City. Penguin Random House’s...

Episode 213 — How to Structure and Implement an ESG Program

Podcasts

7 Nov, 2021

Episode 213 — How to Structure and Implement an ESG Program

As companies focus more on ESG, it is obvious that companies will achieve a significant number of benefits beyond that defined in the ESG acronym. A well-designed and tailored program will bring significant benefits to the overall company’s operations. There are a number of important issues that design and implementation of an ESG program entail. It is hard to fill in many of the important...

Ransomware and OFAC Sanctions Compliance

General

4 Nov, 2021

Ransomware and OFAC Sanctions Compliance

We have all read about the high-profile malicious cyber-attacks and ransomware demands and payments. The Colonial Pipeline case demonstrated how responsive law enforcement can be in tracking down perpetrators and recovering ransom payments. The Treasury Department’s Office of Foreign Asset Control (“OFAC”) has a vested interest in this enforcement arena. On September 21, 2021, OFAC issued an updated ransomware advisory on the topic (“Updated Advisory”)....