individual prosecution Archives - Corruption, Crime & Compliance

21 Dec, 2021

OFAC Collects $133k from a US Individual for Violations of Iran Sanctions Program

In May 2019, OFAC released its Framework for a Sanctions Compliance Program. OFAC announced that it intended to increase the prosecution of individuals for sanctions violations. OFAC has brought two cases against individuals, and last week settled its third case against an individual since its May 2019 announcement. The latest case involves prohibited transactions with Iran relating to the cement clinker business. The individual, a...

Too Big to be Accountable: The Big Case Dilemma

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23 Nov, 2020

Too Big to be Accountable: The Big Case Dilemma

Over the last twenty year (yes, 20 years), the Justice Department’s civil and criminal enforcement record has come under greater scrutiny. Whether you call it “Too Big To Jail” or “Too Big to Fail,” questions continue to rise on whether “big” companies are fairly investigated and prosecuted. On the “Too Big to Fail” scale. DOJ and criminal justice commentators point to the Arthur Andersen criminal...

General

25 Aug, 2016

Thinking Like a Prosecutor – Yates and Internal Investigations

I respect prosecutors, most of them at least. I had the fortunate opportunity to work with a number of terrific prosecutors. Most are intelligent, hard working and committed to doing the right thing. I recognize that there are times when a prosecutor crosses the line, and for those prosecutors, I have no sympathy. Whatever punishment they receive is usually well deserved. But a very high...

General

24 Jan, 2016

Prosecuting Individuals – The Coming Wave

When the Justice Department adopts new strategies and policies, it takes time for results. Rest assured, however, that the Justice Department’s focus on individual accountability is going to have real and significant consequences. The political blowback to DOJ’s prosecution strategies started with the failure to indict or seriously investigate senior executives connected to financial institutions involved in the financial crisis of 2008 to 2009. The...