Tagged: Corporate monitor

FLIR Systems ITAR Settlement Outlines Important Export Compliance Factors (Part II of II)

The FLIR Systems settlement is an extraordinary event given the sheer number of violations, the systemic breakdown that occurred, and the absence of any meaningful compliance controls.  It is all the more surprising given the fact that FLIR’s operations are devoted in large proportion to the highly-regulated international defense industry market.  Given the level of risk, you would expect FLIR to have in place systems...

Where O’ Where Did Our Monitors Go? — The Telia Bribery Case

Just when everyone was anticipating the beginning of an uptick in FCPA enforcement in 2017, the Justice Department and the SEC delivered a resounding message to remind everyone that FCPA enforcement is here to stay. However, the Telia decision may be the first indication of some changes in DOJ’s FCPA enforcement policies. It is hard to say from just one major DOJ enforcement action but...