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...
Bit Mining, formerly 500.com, was a doomed company from the beginning, When a CEO orchestrates a bribery scheme with the assistance of other senior executives, shareholders and the public have little chance of ensuring a business operating with ethics and integrity. 500.com’s future was sealed when it embraced bribery as a means to avoid head-to-head competition against established US and European companies seeking to enter...
Earlier this year, Bit Mining and its CEO fell under the FCPA hammer. Bit Mining, formerly known as 500.com, resolved investigations with the Justice Department and the SEC for its corrupt scheme to bribe Japanese government officials. On the same date, DOJ announced the indictment of Zhengming Pan, Bit Mining’s former CEO and a Chinese national, for FCPA violations. BIT Mining entered into a three-year...
The Justice Department is about to undergo some fundamental changes. The 2nd Trump Administration will take some initial broad strokes designed to increase accountability and control of prosecutors and laws enforcement. The FBI The first on the chopping block is the FBI. Under existing law, the FBI is a component of the U.S. Department of Justice, presumably under the control and oversight of the Attorney...
As the dust settles on the U.S. Election, companies are quickly analyzing the impact for businesses, federal civil and criminal enforcement priorities and the implications for ethics and compliance. When a new Administration comes into power, change is inevitable and can be far-reaching. Given the change with President Trump’s return to the White House, and in light of several of his stated intentions, companies should...
Teva Pharmaceuticals USA Inc. (Teva USA) and Teva Neuroscience Inc. (“Teva”) agreed to pay $450 million to resolve two matters that allege Teva violated the Anti-Kickback Statute (AKS) and the False Claims Act (FCA). Teva is the largest generic drug manufacturer in the United States. The settlement resolved two alleged kickback schemes: Medicare Cost-Sharing Scheme and Copay Assistance Foundations First, Teva has agreed to resolve...
TD Banks’ complete compliance disaster was reflected in every aspect of TD Bank’s business and compliance operations. It is not surprising that TD Bank’s deficient BSA and AML compliance program was known by its Board of Directors and senior leadership. TD Bank’s priority on business — even illegal business — outweighed all interest in implementing and maintaining an effective BSA and AML compliance program. ...
