C-Suite misconduct Archives - Corruption, Crime & Compliance

8 May, 2018

Compliance Lessons Learned from Panasonic Avionics $280 Million FCPA Enforcement Action (Part II of II)

The Panasonic Avionics (PAC) FCPA enforcement settlement for $280 million with the Justice Department and the Securities and Exchange Commission contains a number of important lessons learned. The overall scope and breadth of PAC’s misconduct was significant and reflects the absence of a meaningful compliance program and commitment to a culture of ethics. Here are the important lessons learned: C-Suite Misconduct: PAC is yet another...

General

31 Jan, 2018

Criminal Enforcement Against Senior Executives: The Fish Rots from the Head

The compliance community is well aware of the risks in the C-Suite. As you move up the corporate ladder, the level of risk from executive misconduct increases. A rotten executive can quickly bring down a company, destroy its reputation, and raise a host of legal and reputational problems. I have written numerous times on the importance of assessing C-Suite risks and building compliance and financial...

General

31 Jan, 2017

C-Suite Misconduct Results in Sociedad Quimica Y Minera FCPA Resolution with DOJ and SEC

In an unusual FCPA enforcement action, the Justice Department and the SEC resolved FCPA violations against Sociedad Quimica y Minera, a Chilean chemical and mining company, for a total of $30.5 million, for paying approximately $15 million in bribes to Chilean officials. SQM agreed to a deferred prosecution agreement (DPA) with DOJ and to assignment of a two-year independent compliance monitor. The odd aspect of...