Featured Articles:

Apple and Amazon Fall to OFAC Enforcement for “Screening Errors” (Part III of III)

It is hard to argue that Apple and Amazon do not have the resources to implement state-of-the-art OFAC compliance programs. After all, the two largest companies in the world should stand as beacons of compliance with the full support of senior management, robust compliance departments, and sophisticated automated systems to support their compliance efforts.  Apple Even the mighty can fall – Apple agreed to pay...

OFAC Enforcement Cases Focused on “Screening Errors”: American Express and Cobham Metalics (Part II of III)

In the last two years, OFAC has brought four enforcement actions that focus on an organization’s “screening errors.” These include: American Express; (2) Cobham Metalics; (3) Apple; and (4) Amazon. In today’s posting, I will review American Express and Cobham Metalics. American Express On April 30, 2020, OFAC issued a Finding of Violation (with no penalty) against American Express Travel Services for violations of  the...

OFAC Enforcement and “Screening Errors” (Part I of III)

Here is another profound grasp of the obvious (for which I have a knack for delivering) – compliance and legal professionals can learn a number of lessons from individual enforcement actions.  In many cases, however, there is much more to the story than the headline or the list of so-called lessons learned. One category of enforcement actions is a perfect example – OFAC has brought...

ComplianceLine & The Volkov Law Group Webinar: Effective Management of Employee Reporting Systems

Effective Management of Employee Reporting Systems  August 12, 2020, Noon EST Sign Up Here. The compliance and ethics hotline represents one of the most integral tools available to a high-functioning Compliance Department.  Companies that implement and properly manage their reporting hotlines create a more positive and robust organizational culture.  In this webinar, Michael Volkov explains how to effectively manage your employee reporting system to create...

OFAC On A Roll: Whitford Worldwide Company Agrees to Pay $824k for Violations of Iran Sanctions

When you are hot, you are hot.  (And when you are not, you are not; Thank you Jerry Reed, Country Singer).  OFAC is hot and resumed its enforcement streak, settling three enforcement actions in three weeks.  The latest settlement involved Whitford Worldwide Company (Whitford”), a cookware manufacturer based in Pennsylvania, which agreed to pay $824,314 for violations of the Iran Sanctions.  Whitford’s liability stemmed from...

Episode 154 — Artificial Intelligence, Data Risk Management: Interview of Christian Focacci from Steele Compliance Solutions

Steele Compliance Solutions announced the global rollout of its new “Risk Intelligence Data” platform.  Companies are suffering from information overload — with new technologies, companies can manage information to increase efficiency and accuracy in collecting and analyzing information needed for risk management purposes. Risk Intelligence Data involves the hybridization of over 5 million of highly trusted risk and compliance sources worldwide, spanning global financial crime...

Oklahoma City Hospital, Management Company, And Physician Group To Pay $72.3 Million To Settle Federal And State False Claims Act

The Justice Department’s enforcement programs are resuming – False Claims Act, FCPA and other programs will continue.  The rate of enforcement, however, is subject to change once again from the impact of the pandemic. As the pandemic continues to spread, DOJ focus on pandemic related fraud and other scams will divert resources from “traditional” priorities. DOJ’s commitment to False Claims Act prosecutions in the health...

Indivior Solutions Pleads Guilty to False Statements and Agrees to Pay $600 Million to Resolve Criminal and Civil investigations for Marketing of Opioid Addiction Treatment Drug Suboxone

DOJ’s aggressive enforcement of the opioid industry is a striking example of the power of federal prosecutors when focused on an industry.  Once prioritized for enforcement, DOJ has quickly brought together prosecutors and law enforcement to target corporate actors and companies with the full force of criminal and civil statutes. In a significant case, DOJ announced the resolution of its criminal and civil investigations against...

DOJ Criminal Generic Pharma Price-Fixing Investigation Gathers Steam: Taro Pharmaceuticals Agrees to Pay DOJ Total of $419 Million

The DOJ Antitrust Division’s multi-year criminal cartel investigation of the generic pharmaceutical industry is gaining steam.  The latest company to settle is Taro Pharmaceuticals which agreed to enter a deferred prosecution agreement and pay a $205.7 million penalty to resolve charges relating to a criminal price-fixing conspiracy.  The Antitrust Division’s settlement with Taro is the 10th case, and the 6th company to be charged or...

DOJ and OFAC Settle with UAE Company for $665,112 for Violations of North Korea Sanctions

The Justice Department and OFAC announced a settlement with Essentra FZE Company Limited (“Essentra FZE”), a cigarette filter and tear tape manufacturer, for violation of the North Korea Sanctions Program.  The violations were based on payments for goods that were received by a foreign branch of a U.S. bank.  Essentra FZE, a UAE company, manufactures and sells cigarette filters and tear tape for customers in...