German-based software company SAP agreed to pay more than $220 million as part of resolutions with authorities in the United States and South Africa regarding alleged violations of the Foreign Corrupt Practices Act.
Internal Investigations
Posted inBoards & Shareholders
Ex-BP CEO facing up to $41M in losses over colleague relationship dishonesty
The board of British oil and gas giant BP announced its remuneration determinations after finding former CEO Bernard Looney committed “serious misconduct” in his disclosure of personal relationships with company colleagues.
Posted inRisk Management
DOJ sets expectations for SEC cyber incident disclosure delays
Companies won’t have an easy path toward earning additional time from the Department of Justice regarding the disclosure of a material cybersecurity incident to the Securities and Exchange Commission as required under a new rule.
Posted inAnti-Bribery
Five compliance triumphs from 2023
A financial services giant’s compliance mea culpa that could serve to benefit the rest of the profession, a chemical company’s praised FCPA settlement, and an example of the value of whistleblowers highlight CW’s annual list of laudable ethics and compliance moments.
Posted inRisk Management
FBI guidance: How to earn delay on SEC cyber incident disclosures
Businesses seeking additional time before disclosing to the Securities and Exchange Commission the occurrence of a material cybersecurity incident must be prepared to provide detailed information on the matter to the Federal Bureau of Investigation.
Posted inEthics & Culture
Tackling off-channel communications? Don’t forget ephemeral messaging
As if creating policies and procedures to handle employee use of off-channel communications is not difficult enough, ephemeral messaging platforms can make it even more difficult to recover messages in transit.
Posted inAnti-Bribery
DOJ cooperation credit breakdowns: Albemarle, Tysers, H.W. Wood
Nicole Argentieri, acting head of the Department of Justice’s Criminal Division, breaks down where Albemarle, Tysers Insurance Brokers, and H.W. Wood went right—and wrong—on the cooperation credit and remediation fronts as part of their FCPA settlements with the agency.
Posted inAnti-Bribery
Lifecore Biomedical earns FCPA declination for voluntary self-disclosure
Pharmaceuticals company Lifecore Biomedical won’t face prosecution for apparent violations of the Foreign Corrupt Practices Act after satisfying multiple factors of the Department of Justice’s recently updated voluntary self-disclosure policy.
Posted inRisk Management
Crisis management: Know the facts, keep communications clear
A panel of legal experts breaks down how to handle an all-out crisis, from whom to involve, what to disclose to regulators, and how to conduct a proper investigation.
Posted inRegulatory Enforcement
CFPB: Citi to pay $26M over Armenian American discrimination
Citi agreed to pay $25.9 million in fines and redress as part of a settlement with the Consumer Financial Protection Bureau addressing allegations the bank discriminated against credit card applicants identified as Armenian American.
