Corruption, Crime & Compliance
Bribery, FCPA, AML
Episode 239 — DOJ’s New CCO Certification Requi...
The Department of Justice continues to respond to the compliance community’s concerns about the new certification requirement adopted as part of the Glencore FCPA enforcement action. DOJ has adopted this new requirement to “empower” CCOs and to ensure ...
29 min
Episode 238: 2022 FCPA Enforcement Trends . . ....
In following the Justice Department and the Securities Exchange Commission FCPA enforcement actions, I am always reminded of the popular phrase — “reading the tea leaves.” (or “tasseography,” a fortune-telling method based on tea leave patterns in tea ...
27 min
Episode 237 — The Tenaris SEC FCPA Settlement
The SEC announced another FCPA settlement in 2022. FCPA enforcement, in general, is picking up. Tenaris, a global supplier of steel pipes and related services for the energy industry agreed to pay the SEC $78 million to resolve FCPA violations that occ...
21 min
Episode 236 — The Glencore FCPA and Fraud Settl...
In a long-anticipated and major enforcement action, the Justice Department and the Commodities and Futures Trading Commission resolved a sprawling investigation with Glencore International A.G. and Glencore Ltd,
33 min
Episode 235 — Third-Party Risk Management
The global economy has suffered two significant shocks — first, the pandemic sent shockwaves through every organization, and second, the war in Ukraine. Both of these events exposed the importance of risk management,
37 min
Episode 234 — A Deep Dive into the Stericycle F...
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.
26 min
Episode 233 — Tom Fox and Mike Volkov Discuss D...
Federal prosecutors know that their job – to represent the United States – is the highlight of their legal career. Speaking from experience, federal prosecutors are a privileged lot – they can announce in court they represent the United States.
31 min
Episode 232 — OFAC Settles with S&P Global for ...
OFAC recently announced a settlement with S&P Global for $78,750 for violations of the Ukraine-Russia Sanctions Program. The enforcement action provides important reminders relating to compliance with various “debt” maturity restrictions and how OFAC c...
19 min
Episode 231 — SEC Update: Climate Change and Cy...
The SEC is a very busy enforcement agency. While promising more aggressive enforcement of securities rules, the SEC has issued two set of comprehensive rule amendments. The first proposes new rules governing cyber incident reporting,
23 min
Episode 230 — Catching Up with DOJ’s Antitrust ...
The Antitrust Division’s Assistant Attorney General Jonathan Kanter promised a new era in antitrust enforcement.  He won bi-partisan support from both Republicans and Democrats.  Across the antitrust field, he promised aggressive merger enforcement,
20 min