Tagged: DOJ

2 Oct, 2023

Albemarle Settles DOJ and SEC FCPA Cases for $218 Million (Part I of III)

Albemarle Corporation (Albemarle), a specialty chemicals manufacturing company located in Charlotte, North Carolina, agreed to pay more than $218 million to settle FCPA investigations with DOJ and the SEC stemming from bribery payments in Vietnam, Indonesia and India. Albemarle entered into a three-year non-prosecution agreement (“NPA”) with DOJ and agreed to pay a penalty of approximately $98.2 million and an administrative forfeiture of approximately $98.5...

Events

21 Sep, 2023

Webinar: Elevating Your Sanctions and Export Controls Compliance Program

October 24, 2023 12 Noon EST Sign up HERE The Department of Justice warned global companies of a new, aggressive strategy for enforcement of trade sanctions and export controls. DOJ’s message has been reinforced by the Departments of Treasury (Office of Foreign Asset Control, or “OFAC”) as to sanctions, and the Department of Commerce (Bureau of Industry and Security, or “BIS”), as to export controls....

General

20 Sep, 2023

Do We Really Need an ISO Standard for Internal Investigations?

Call me a skeptic. Call me cynical. I understand that the International Organization for Standardization (ISO) provides valuable standardization services and guidance. The ISO is comprised of 169 member countries. The ISO recently issued a new standard governing internal investigations. From my vantage point, I was a critic of ISO 37001, anti-corruption compliance, because of its over-generalization and failure to provide more specific guidance on...

General

13 Sep, 2023

DOJ’s National Security Division Places Corporate Crime in the Crosshairs

Sam Finkelstein, an associate at The Volkov Law Group, rejoins us for a posting on DOJ’s initiative to increase corporate prosecution of sanctions, export controls and national security issues. Sam can be reached at [email protected]. The marriage of corporate enforcement and national security has been a defining feature of the DOJ under the Biden Administration. The Justice Department’s commitment to prosecuting corporate crimes that implicate...

Podcasts

11 Sep, 2023

Episode 289: Justice, Commerce and Treasury Issue Joint Notice on Voluntary Disclosure

In another significant step notifying global businesses of the new realities – companies are about to face aggressive coordinated prosecutions for sanctions and export control violations. The last piece in launching this new effort was the announcement of a joint voluntary disclosure program to ensure alignment among the agencies for civil and criminal enforcement of such violations. The Joint Compliance Note (“JCN”) urges companies to...

General

15 Aug, 2023

The Corficocolombiana FCPA Settlement: the Bribery Scheme (Part II of II)

You can always learn a lot from reviewing the underlying conduct to an FCPA enforcement action. Chief compliance officers can identify specific risk factors, mitigation steps and root causes for bribery schemes. The Corficocolombiana (“Corfico”) FCPA settlement underscores the significant risks when companies participate in large projects in foreign countries. Between 2012 and 2015, Corfico paid more than $23 million in bribes to high-ranking Colombian...

General

14 Aug, 2023

Corficocolombiana and Grupo Aval Pay $80 Million to Settle DOJ and SEC FCPA Violations in Colombia (Part I of II)

The Department of Justice has been relatively quiet this year in bringing corporate FCPA enforcement actions and settlements. Aside from the Ericsson breach of its Deferred Prosecution Agreement, the Corficocolombiana (“Corfico”) and Grupo Aval settlement is the first in 2023 involving a corporate FCPA resolution. For the SEC, the Corfico and Grupo Aval settlement is the sixth corporate resolution in 2023. Corfico is a subsidiary...

General

10 Aug, 2023

Justice, Commerce and Treasury Departments Issue Comprehensive Tri-Party Voluntary Disclosure Guidelines for Sanctions and Export Control Violations

In another significant step notifying global businesses of the new realities – companies are about to face aggressive coordinated criminal and civil prosecutions for sanctions and export control violations. The last piece in launching this new effort was the announcement of a joint voluntary disclosure program to ensure alignment among the agencies for civil and criminal enforcement of such violations. The Joint Compliance Note (“JCN”)...

Podcasts

10 Jul, 2023

Episode 280 — Healthcare Compliance and Fraud

Looking back in time, the compliance field owes a lot to the healthcare industry. In the 1990s, there was a dramatic explosion in the industry in response to aggressive federal enforcement programs and increasing regulation. All of a sudden, compliance officers who sat in the backrooms of legal departments were “volunteered” to address proactive compliance. Federal regulators pushed the compliance function to assume a much...

General

29 Jun, 2023

DOJ Arrests 78 Defendants in Nationwide Crackdown on Healthcare Fraud

Healthcare fraud continues to plague the industry – each year Medicare and Medicaid suffer over $100 billion in losses from fraudsters. Prosecuting fraud cases in the healthcare industry is like shooting fish in a barrel – there are an infinite number of targets. To publicize its efforts, each year, DOJ executes multiple nationwide takedowns, rounding up healthcare fraudsters across the nation. In its most recent...