Tagged: DOJ

DOJ Brings First Corporate FCPA Enforcement Action – Settles with Stericycle for $84 Million (Part I of III)

DOJ Brings First Corporate FCPA Enforcement Action – Settles with Stericycle for $84 Million (Part I of III)

The Justice Department ended its FCPA enforcement drought by announcing its first corporate settlement in 2022.  In a parallel action, the SEC announced its settlement with Stericycle for $28 million for FCPA violations.  The SEC’s settlement was its second with a company for 2022 (the first was KT Corp.). Under the settlement, Stericycle resolved investigations being conducted by the Department of Justice, the Securities and...

Ethics and Compliance Initiative Impact 2022 — Sign Up Now!

Ethics and Compliance Initiative Impact 2022 — Sign Up Now!

SIGN UP HERE April 19 – April 22, 2022 IMPACT 2022 is the premier gathering of the year for ethics and compliance officers and practitioners who look to improve their organizational E&C initiatives while increasing efficiency and reducing costs. This year’s event features keynote addresses featuring the United States Department of Justice and the Securities and Exchange Commission. In addition, IMPACT 2022 offers more sessions...

Global Update and Review: Russia Sanctions and Asset Capture Initiatives

Global Update and Review: Russia Sanctions and Asset Capture Initiatives

The Russia-Ukraine crisis has created a fast-moving compliance nightmare – sanctions and export controls around the globe are changing each day.  Some major companies are pulling out of Russia completely in response to the crisis. Others are trying to keep up with sanction requirements and adjusting specific controls each day.  Whatever approach is taken, trade compliance officers have their hands full. United States On the...

Episode 218 — The Biden Administration’s New Strategy on Countering Corruption

Episode 218 — The Biden Administration’s New Strategy on Countering Corruption

The Biden Administration announced a new, comprehensive anti-corruption initiative, the United States Strategy on Countering Corruption. The new anti-corruption initiative is the follow on to the earlier announcement elevating the global anti-corruption battle to a national security concern. After that announcement, the Biden Administration conducted a 200-day inter-agency examination to develop a comprehensive government-wide anti-corruption initiative. The 38-page plan released last week outlines steps for cracking...

DOJ Battles Ransomware Attacks

DOJ Battles Ransomware Attacks

The Justice Department continues to attack and dismantle global ransomware extortion organizations.  Business surveys often confirm that executives are hyper-focused on the risk of ransomware attacks against businesses. Interestingly, government regulators have focused on ransomware scenarios to ensure that regulatory restrictions on sanctions and other restrictions are not violated.  The message behind DOJ and regulatory interests is clear – if attacked, notify law enforcement right...

Rockwell Automation Executives Arrested for Fraudulent Scheme

Rockwell Automation Executives Arrested for Fraudulent Scheme

Little problems can become big ones.  A failure to respond to a risk – whether it is a conflict of interest violation or a weakness in internal controls – can become even more significant depending on the size and scope of the problem. A recent criminal prosecution of two Rockwell Automation executives underscored the nature of this phenomena.  Last month, federal prosecutors arrested and charged...

Deputy AG Lisa Monaco Suggests Major Changes to the DOJ’s Corporate Enforcement Efforts

Deputy AG Lisa Monaco Suggests Major Changes to the DOJ’s Corporate Enforcement Efforts

Alex Cotoia, Regulatory Manager at The Volkov Law Group, rejoins us for a post providing additional color into U.S. Deputy Attorney General Lisa Monaco’s recent announcement on changes to DOJ policies. Alex can be reached at [email protected]. On October 28, 2021, U.S. Deputy Attorney General Lisa O. Monaco—a veteran of government service in previous Administrations and a champion of corporate accountability—announced several significant changes to...

Keeping Track of Third Party Risks – Bribery and Sanctions

We have heard it over and over, again and again – third-parties pose significant risks of bribery for all global businesses.  Almost every FCPA enforcement action includes some form of third-party misconduct.  The current picture from the Stanford FCPA Resource confirms the story. A cottage industry of automated platforms, data analytics, due diligence and monitoring strategies have grown around third-party bribery risk.  Companies have designed...

Here Comes DOJ – Corporate Crime Enforcement

Here Comes DOJ – Corporate Crime Enforcement

Sorry to repeat myself (sorry, but inevitable in my maintaining this blog for 9 years), but the Justice Department, like other enforcement agencies, will tell everyone what they plan to do and then do it.  Not on individual investigations, but in enforcement priorities, strategies and resources.  Lisa Monaco, the Deputy Attorney General (No. 2 in DOJ), delivered an important speech at the National Institute of...

The Forkner Indictment for the Tragic Boeing 737 MAX Fraud and Crashes (Part II of III)

The Forkner Indictment for the Tragic Boeing 737 MAX Fraud and Crashes (Part II of III)

Mark Forkner, a former Chief Technical Pilot, was indicted  on two counts of fraud involving aircraft parts in interstate commerce and four counts of wire fraud.  If convicted, he faces a maximum penalty of 20 years in prison on each count of wire fraud and 10 years in prison on each count of fraud involving aircraft parts in interstate commerce. Boeing began to develop the...