- Chief Compliance Officer and VP of Legal Affairs, Arrow Electronics
By 
Kyle Brasseur2023-11-30T20:54:00
The Department of Justice (DOJ) has made no secret about its incentives for companies to come forward with information on apparent corporate misconduct for the chance to earn discounted or reduced penalties—even a declination.
An example of a successful voluntary self-disclosure is U.K.-based insurance broker Jardine Lloyd Thompson Group Holdings (JLT). The firm was notified in March 2022 it would not face prosecution for alleged bribes paid to Ecuadorian government officials by an employee and other company agents after self-reporting to the DOJ, cooperating with the agency’s subsequent investigation, timely remediation, and agreeing to disgorge more than $29 million in ill-gotten gains.
Case closed for JLT. Cases opened for Tysers Insurance Brokers and H.W. Wood.
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The Department of Justice declined to prosecute Massachusetts-based biochemical company MilliporeSigma for its “extraordinary cooperation” in uncovering a “rogue” employee’s scheme to procure and ship discounted products to China using falsified export documents.
Arthur J. Gallagher disclosed the Department of Justice ended an investigation into the insurance broker’s business in Ecuador for potential violations of the Foreign Corrupt Practices Act.
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.
A lack of supervision and internal controls at Morgan Stanley Smith Barney allowed four of its investment advisers to steal millions from customers before the behavior was detected, the SEC said in charging the firm.
A subsidiary of McKinsey & Co. will pay nearly $123 million to the Department of Justice to settle allegations that it bribed officials in South Africa to win consulting contracts.
A defamation lawsuit filed by a whistleblower against USAA, which a Florida judge recently dismissed on a technicality, revealed in public court records an estimated 400,000 violations of the Military Lending Act by USAA Federal Savings Bank (USAA Bank), an indirect wholly owned subsidiary of USAA.
