This week we are pleased to bring you one of our most popular episodes of 2024. Please enjoy, and we will be back next week with more insights from the Corruption, Crime, and Compliance podcast. Have you heard of the recent controversies around Boeing 737 MAX and its safety? Have you wondered what is being done about the concerns around it? In this episode of...
We live in a topsy-turvy world. This is an exaggeration but sets up my points in this blog post. We are now seeing the shuffling of corporate risks and every board, C-Suite and legal, compliance and risk management team has to take a hard look at your company’s risks and reassess and re-rank them. Initial Review Some basic business and technology risks will stay the...
In 2017, when President Trump first took office, big changes were expected in FCPA enforcement. Much of this reflected President Trump’s expressed misgivings on the substance of the FCPA. He was not a big fan of the law and made his opinion known. The Trump Administration, however, did not dismantle FCPA enforcement and in fact, DOJ and the SEC increased FCPA enforcement. DOJ and the...
Can the DOJ’s commitment to holding individuals and corporations accountable under the FCPA survive the changing political climate in 2025? Will the push for innovation in corporate compliance programs be enough to maintain momentum, especially with emerging technologies like artificial intelligence? In this episode of Corruption, Crime and Compliance, Michael Volkov dives deep into the FCPA enforcement landscape of 2024, outlining key cases, changes in...
Criminals can be creative — that is a true statement but essentially FCPA criminals have to embrace a variety of well-established techniques to accomplish a straight-forward goal — steal money from the company to funnel bribery payments to foreign officials. The complement of 2024 FCPA cases saw some of our standard techniques (or schemes) but a few presented some new twists. To help organize these...
With the end of the Biden Administration, it is hard to identify a consistent theme relating to FCPA enforcement. On the one hand, the Biden Administration talked a big game, elevating the anti-corruption fight as a national security priority and promising even more aggressive FCPA enforcement than the prior Trump Administration. At the same time, the Justice Department modified its Corporate Enforcement Policies, tightening the...
How did a high-stakes bribery scheme involving insider deals, Airbus planes, and secret payments bring down a global aviation giant? In this episode, Michael Volkov dives deep into the AAR Corporation FCPA case—a cautionary tale of bribery, insider deals, and compliance failures in high-risk sectors. The DOJ and the Securities and Exchange Commission (SEC) closed 2024 with a major coordinated settlement with AAR Corporation, a...
The Justice Department and the SEC finished 2024 with a coordinated resolution of criminal and civil FCPA charges against AAR Corporation, an Illinois-based provider of aviation products and services. In addition, DOJ unsealed a criminal indictment and guilty plea dated August 1, 2024, by Deepak Sharma, CEO of an AAR Subsidiary for his role in the FCPA scheme. Also, the SEC entered into a separate civil...
What went wrong when McKinsey paid bribes to secure consulting contracts with South Africa’s state-owned enterprises? In this episode, Michael Volkov dives into the December 2024 DOJ settlement with McKinsey & Company, which paid $122 million after being found guilty of paying bribes to officials at Transnet and Eskom to secure valuable consulting contracts. The case involved significant violations of the Foreign Corrupt Practices Act...
What happens when a Chief Executive Officer becomes the architect of a global bribery scheme? In this episode of Corruption, Crime, and Compliance, Michael Volkov delivers an in-depth analysis of the BIT Mining FCPA case — a landmark matter that underscores the severe consequences of C-suite misconduct. With CEO Zhengmin Pan at the center of the conspiracy, BIT Mining’s efforts to infiltrate Japan’s emerging casino...
