Corruption, Crime & Compliance

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2 Dec, 2020

Webinar: Monitoring Your Third Parties — Digging into Distributor and Agent Risks

Webinar: Monitoring Your Third Parties — Digging into Distributor and Agent Risks December 15, 2020, 12 Noon EST Sign Up HERE Government enforcement actions against companies for anti-corruption, sanctions, money laundering and accounting misconduct often focus on third-party risks. And for good reason — government enforcement actions almost always cite third-party misconduct and complicity in illegal schemes to pay bribes, circumvent sanctions and launder money....

General

1 Dec, 2020

HHS-OIG Warns Drug and Device Companies on Speaker Program Fraud

In a far-reaching action, the Health and Human Services – Office of Inspector General (HHS-OIG) issued a Special Fraud Alert underscoring the “inherent fraud and abuse risks” associated with company-sponsored speaker programs. Copy of Special Alert Here. HHS-OIG’s Fraud Alert is an important warning to pharmaceutical and medical device companies. It directly applies to U.S. companies’ domestic speaker programs, but the analysis and observations have...

General

30 Nov, 2020

Citigroup Fined $400 Million by Banking Regulators for Risk and Compliance Control Deficiencies

Banking regulators, the Office of Comptroller of the Currency and the Federal Reserve, recently collected a $400 million civil penalty against Citigroup for long-standing deficiencies in its enterprise risk management, compliance controls and overall banking practices. The Consent Order is Here. The aggressive enforcement action was the result of Citigroup’s continuing deficiencies in its operations, risk oversight and management practices. The OCC cited Citigroup for...

Podcasts

29 Nov, 2020

Episode 171 — Promoting an Ethical Culture: Interview of Jeffrey Tilton

The Justice Department and regulatory agencies have emphasized the importance of corporate culture and ethics. As companies approach this important issue, it is important to examine a variety of strategies to ensure that a corporate culture adheres to ethical standards. Jeffrey Tilton, CFE, a leader in the compliance field, has an interesting perspective on this issue. In this Episode, Michael Volkov discusses the issue of...

General

25 Nov, 2020

Happy Thanksgiving!

To our clients, colleagues, and friends, we wish everyone a Happy Thanksgiving!! We are grateful for opportunities to collaborate, and our deep appreciation for your support and friendship. Our very best wishes for a happy and safe Thanksgiving!!

General

23 Nov, 2020

Too Big to be Accountable: The Big Case Dilemma

Over the last twenty year (yes, 20 years), the Justice Department’s civil and criminal enforcement record has come under greater scrutiny. Whether you call it “Too Big To Jail” or “Too Big to Fail,” questions continue to rise on whether “big” companies are fairly investigated and prosecuted. On the “Too Big to Fail” scale. DOJ and criminal justice commentators point to the Arthur Andersen criminal...

General

23 Nov, 2020

OFAC Screening and Internal Controls

Companies have had over one year to review and implement a sanctions compliance guidance program. This last year, however, has been difficult (to say the least) given the COVID-19 pandemic. Companies have had unusual challenges. OFAC recognized the impact of COVID-19 when it issued guidance in April 2020 recognizing that companies faced challenging times and may have reallocated resources to meet pandemic needs. Prior to...

Podcasts

22 Nov, 2020

Episode 170 — The Beam Suntory FCPA Settlement

Beam Suntory, a global producer and distributor of distilled beverages, settled its FCPA case with DOJ for $19.5 million for bribes paid in India. The DOJ settlement follows an SEC FCPA settlement for $8 million announced on July 2, 2018. The timing of the FCPA settlements is unusual and suggests that DOJ’s resolution involved unique issues relating to Beam Suntory’s cooperation. In this Episode, Michael Volkov...

General

20 Nov, 2020

Analysis of DOJ’s Antitrust Case Against Google (Part III of III)

DOJ’s antitrust case against Google presents several interesting and difficult issues. Google dominates the search engine market. No one can question that. But the question will eventually boil down to whether Google’s conduct, as a monopolist, resulted in consumer harm. Section 2 monopolization cases require more proof than whether a specific company has a monopoly. The question boils down to whether Google engaged in exclusionary...

Events

19 Nov, 2020

Webinar: Antitrust Enforcement and Compliance Trends

Webinar: Antitrust Enforcement and Compliance Trends December 1, 2020 12 Noon EST Sign up HERE The Justice Department Antitrust Division’s criminal enforcement program has been gaining steam. DOJ has focused on the generic pharmaceutical industry, chicken processing, Florida-based oncology treatment and recently launched its procurement collusion task force. For many global companies, criminal antitrust enforcement is a significant risk. It is important that global companies...