Corruption, Crime & Compliance

Featured Articles:

30 Sep, 2021

Cameron Settles OFAC Case for $1.4 Million for Violation of Ukraine-Russia Sanctions (Part I of II)

In a pair of enforcement actions, here and here, OFAC settled two separate actions involving Schlumberger Limited subsidiaries – the first involving Cameron International Corporation, and the second, Schlumberger Rod Lift, Inc., a former subsidiary, that was acquired by Lufkin Rod Lift, Inc. Cameron agreed to pay $1.423 million to settle OFAC charges for providing services to the Gazprom-Neft Shelf for an Arctic offshore oil...

General

30 Sep, 2021

DOJ Ends Standoff & Agrees to DPA with Huawei CFO Wanzhou Meng

The long political and prosecution standoff between the U.S. Government/Department of Justice and Huawei/China ended abruptly last week when Wanzhou Meng, CFO of Huawei Technologies Co., Ltd. appeared in federal district court in Brooklyn and entered into a deferred prosecution agreement (DPA) and admitted to misleading global financial institutions. Meng was immediately released and returned to China. The resolution of Wanzhou Meng’s case resolved a...

General

29 Sep, 2021

WPP SEC FCPA Enforcement Action: Lessons Learned (Part III of III)

The SEC’s FCPA enforcement action against WPP presents a number of important lessons learned, ranging from third-party risk management, properly responding to employee complaints and red flags, and failure to integrate acquisition targets into existing compliance programs. At bottom, WPP and its subsidiaries lacked any culture of compliance. While it is easy to cite all the deficiencies in the WPP subsidiaries, such a focus misses...

General

28 Sep, 2021

A Deep Dive into WPP’s Bribery Schemes in India, China, Brazil and Peru (Part II of III)

The SEC’s FCPA settlement with WPP for over $19.2 million provides a variety of bribery schemes in several high-risk venues. The schemes are instructive because they remind anti-corruption compliance professionals of the number of ways in which bribery can be carried out. In this way, the SEC’s enforcement action is informative and contains helpful reminders on various risks in the anti-corruption arena. India: In July...

General

27 Sep, 2021

WPP, the Largest Global Advertising Group, Settles FCPA Charges with SEC for $19.2 Million (Part I of III)

After a long hiatus, the SEC announced a settlement with WPP plc, the world’s largest advertising group, for FCPA violations in India, China, Brazil and Peru for $19.2 million. The SEC’s resolution charges WPP with violations of the anti-bribery, books and records and internal accounting controls provisions of the FCPA. The Justice Department’s investigation of WPP appears to be ongoing. WPP has dual headquarters, in...

Podcasts

26 Sep, 2021

Episode 207 — Common Pitfalls in Conducting Internal Investigations

An internal investigation is like reading a good novel. You begin the journey with a general expectation of what the novel or the “investigation” is about. As you learn more, the investigation gains momentum filled with moments of discovery, surprise and ultimately a basis for understanding. In some cases, the end of the story (e.g. an oil well explosion) or dramatic event is known. In...

General

23 Sep, 2021

4 Requirements for a Healthy Relationship Between a CCO and the Corporate Board

Chief compliance officers need the support and advocacy of the corporate board to have a chance to succeed. A CCO has many important relationships to protect and nurture within the company. None is more important that the CCO’s relationship with the Board. In recognition of this basic requirement, CCOs have to dedicate themselves to building a strong and positive relationship. A basic list of four...

General

22 Sep, 2021

Former Ericsson Employee Indicted for Role in Foreign Bribery Scheme

In a surprising (but fully warranted) twist, the Justice Department returned an indictment against a former employee of Telefonaktiebolaget LM Ericsson (“Ericsson”), a global telecommunications company, for his role in paying approximately $2.1 million in bribes to high-level government officials in the Republic of Djibouti. Afework “Affe” Bereket, 53, a dual citizen of Ethiopia and Sweden, was charged in a two-count indictment – Count 1...

General

21 Sep, 2021

The Big “G” in ESG – CCOs Need to Embrace ESG as a Compliance Opportunity

Chief compliance officers can occasionally suffer from a “complex” (akin to the Jungian one). CCOs and their priorities are often pushed aside in favor of “more important” corporate initiatives. CCOs are used to fighting for their initiatives and standing firm when challenged by so-called “competing” priorities. ESG is not a threat to compliance; it is an opportunity. CCOs cannot be shy when it comes to...

General

20 Sep, 2021

NewTek, Inc., a Software Provider, Settles OFAC Violations for $189,483

The Treasury Department’s Offices of Foreign Assets Control (“OFAC”) continues its enforcement run in 2021, and added yet another tech company to its list of targets. NewTek, Inc. (“NewTek”), a software provider that develops and supplies live production and 3D animations hardware and software, agreed to pay $189,483 to settle 52 violations of the Iran Sanctions Program. NewTek’s violations arose from its sales to foreign...