Internal Investigations

DOJ building


The path to DOJ cooperation credit: Analyzing recent FCPA cases


Recent enforcement actions offer guidance on what the Department of Justice considers to be an “imminent threat” of disclosure or government action, what it means by “prompt” disclosure, and how a company can earn credit for revealing all relevant facts.

Sterling Bank

News Brief

Ex-Sterling Bank GC cited by OCC over BSA-related failures


The Office of the Comptroller of the Currency issued a cease-and-desist order against the former general counsel at Sterling Bank and Trust for not ensuring the institution’s Bank Secrecy Act compliance and failing to timely file suspicious activity reports.


News Brief

Zoetis says no action from OFAC in Iran sanctions matter


Zoetis, a developer and manufacturer of vaccines and medicines for animals, disclosed it was informed by the Office of Foreign Assets Control that it won’t face enforcement for potential violations of Iran sanctions uncovered during an acquisition integration.



Experts: SCOTUS ruling shifts onus to employers in whistleblower cases


The Supreme Court’s unanimous decision to reaffirm whistleblower protections under the Sarbanes-Oxley Act in a case involving UBS has wide ramifications in many other industries beyond financial services, according to legal experts.

Supreme Court

News Brief

SCOTUS reaffirms whistleblower protections in ruling against UBS


The Supreme Court reaffirmed whistleblower protections guaranteed under the Sarbanes-Oxley Act in a unanimous decision expected to set a precedent that impacts all corporate internal reporting cases.


News Brief

Raytheon parent discloses indications of improper payments in Middle East


RTX Corp., parent company of aerospace and defense giant Raytheon, disclosed an internal investigation launched into potential improper payments in connection with contracts in the Middle East found indications of misconduct.

Accounting investigation

News Brief

China-based Cloopen Group avoids fine in SEC accounting fraud case


China-based technology company Cloopen Group Holding won’t pay a fine in settling with the Securities and Exchange Commission over an alleged accounting fraud scheme perpetrated by two of its former senior managers.

Data breach


Experts: Good data breach response grounded in preparation


Two chief compliance officers and an attorney discussed preparation for the “when, not if” threat of a data breach during a panel at CW’s Cyber Risk & Data Privacy Summit.


News Brief

Calavo Growers discloses potential FCPA issues


Multinational produce and agriculture company Calavo Growers disclosed in an annual filing an investigation into its Mexico operations found potential issues under the Foreign Corrupt Practices Act.



FCPA violations in China: Lessons learned from 2023 cases


Enforcement actions regarding alleged violations of the Foreign Corrupt Practices Act at 3M, Albemarle, Clear Channel Outdoor, and Royal Philips each had China touchpoints. Experts assess third-party risk management lessons learned from each case.


News Brief

ADM puts CFO on leave pending accounting probe


Food processing company ADM announced Chief Financial Officer Vikram Luthar was placed on administrative leave pending an investigation into accounting practices and procedures flagged by the Securities and Exchange Commission.


News Brief

ICBC fined $32M by NYDFS, Fed over compliance lapses


The Industrial and Commercial Bank of China and its New York branch agreed to pay $32.4 million in penalties levied by two regulators for failing to address compliance failures and for the unauthorized disclosure of confidential supervisory information to an overseas regulator.

Business data


Lessons from Albemarle, ABB: How data-driven compliance can help your firm


Andrew McBride, chief risk officer of Albemarle Corp., and Tapan Debnath, head of integrity, regulatory affairs and data privacy at ABB, discussed how and why their respective organizations use data analytics to conduct business as part of a recent webcast.


News Brief

SAP to pay $220M in FCPA settlements


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.


News Brief

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.


News Brief

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.

Discover Financial Services


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.

FBI logo

News Brief

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.



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.

Albemarle web


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.

DOJ wall

News Brief

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.

Crisis 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.

Citi building

News Brief

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.

China scrutiny


Due diligence in China: Mitigating arrest, detention risks


Lack of transparency around how to remain within the legal bounds of China’s national security laws has heightened companies’ concerns regarding performing on-site due diligence in the country.

Fraud victim

News Brief

FCA review finds fraud victim support lacking


Payment service providers could do more to support victims of fraud, including through better communication procedures, a review by the U.K. Financial Conduct Authority found.

SEC headquarters


SEC’s Grewal calls for more self-policing in reflecting on FY23 cases


Businesses must step up their internal policing and do a better job of reporting violations to the Securities and Exchange Commission, according to Gurbir Grewal, director of the agency’s Enforcement Division.

Mohawk Industries

News Brief

Mohawk says no SEC enforcement regarding $60M securities litigation


Flooring manufacturer Mohawk Industries disclosed it does not expect to face enforcement from the Securities and Exchange Commission regarding allegations of violations of securities laws raised in a class-action lawsuit that the company agreed to pay $60 million to settle.


News Brief

Albemarle to pay $218M in FCPA settlements with DOJ, SEC


Chemical company Albemarle was assessed penalties totaling more than $218 million as part of settlements with the Department of Justice and Securities and Exchange Commission addressing alleged violations of the Foreign Corrupt Practices Act across a handful of foreign countries.


News Brief

Clear Channel Outdoor to pay $26M in FCPA case over China bribes


Clear Channel Outdoor Holdings agreed to pay more than $26 million as part of a settlement with the Securities and Exchange Commission alleging its former China-based subsidiary bribed government officials to obtain outdoor advertising contracts.

SEC office

News Brief

GTT Communications spared fine in SEC disclosure failure case


GTT Communications, a provider of telecommunications and internet services, avoided a civil penalty in reaching a settlement with the Securities and Exchange Commission addressing alleged disclosure failures over more than a two-year period.


News Brief

Swedish DPA fines Trygg-Hansa $3.2M for GDPR breaches


Sweden’s data protection authority issued a penalty of 35 million Swedish krona (U.S. $3.2 million) against insurance company Trygg-Hansa for alleged security flaws that made customer insurance information accessible on the internet.


News Brief

Lovesac facing shareholder pressure over accounting errors


The Lovesac Company disclosed it expects to restate certain of its 2023 financial statements after an internal investigation uncovered accounting errors related to its recording of last mile freight expenses.


News Brief

​Grupo Aval to pay $81M in landmark FCPA case


Colombian conglomerate Grupo Aval agreed to pay nearly $81 million as part of settlements addressing alleged bribes paid by its bank subsidiary Corficolombiana to win a highway construction contract.



​SEC’s latest whistleblower award worth note beyond $104M payout


The SEC announced a $104 million award split among seven whistleblowers, but the fact nearly a dozen claimants contacted the agency seeking to provide information related to one action should be notable to companies regarding the stakes of the current whistleblower landscape.


News Brief

Albemarle reserves $219M for FCPA settlements


Chemical company Albemarle Corp. disclosed it is set to pay $218.5 million as part of proposed settlements reached with the Department of Justice and Securities and Exchange Commission regarding apparent violations of the Foreign Corrupt Practices Act.



Financial crime investigations: Leveling up

2023-08-01T15:54:00+01:00By James Thomas, International Compliance Association

The drive toward upskilling in the field of investigations is not exclusive to the law enforcement and intelligence communities. Investigations knowledge and expertise among those working within industry will also become an increasingly valued commodity.



Supreme Court to consider case that could affect corporate whistleblowing


The Supreme Court agreed to hear arguments in a case, Murray v. UBS Securities, that has focused attention on the burden of proof whistleblowers reporting misconduct internally must meet to establish retaliation by their public company employer.


News Brief

​PwC Australia removes chief risk officer after tax scandal review


PwC Australia exited eight partners, including its former chief risk and reputation officer, following an investigation into the sharing of confidential government tax policy information at the firm.

Stanley Black & Decker

News Brief

​Stanley Black & Decker avoids fine in SEC executive perks case


Tool manufacturer Stanley Black & Decker avoided a civil penalty in settling with the Securities and Exchange Commission regarding alleged violations of executive perk disclosure rules.



Nutanix discloses remediation steps following costly software misuse


A lack of oversight of employees handling vendor software is one of several failings at cloud computing company Nutanix that led to misuse, $11 million in estimated costs, and two pending lawsuits.

Culture panel CW2023


CW2023 panel: Taking on the corporate culture monster


A trio of panelists offered a framework and strategy for embedding ethical culture into organizations at Compliance Week’s 2023 National Conference.

Compliance and HR CW2023


‘Elephant in the room’: Combating tension between compliance, HR


Regulators are collaborating—both domestically and internationally—more than ever before. And they expect companies to be doing the same, noted panelists during a session on collaboration between compliance and human resources at Compliance Week’s 2023 National Conference.


News Brief

Philips to pay $62M to settle alleged FCPA violations in China


Dutch conglomerate Royal Philips will pay more than $62 million to settle allegations it violated the Foreign Corrupt Practices Act when its subsidiaries engaged in improper conduct to win contracts in China.


News Brief

Frank’s International to pay $8M in FCPA case


Dutch oilfield services provider Frank’s International agreed to pay nearly $8 million as part of a settlement with the Securities and Exchange Commission for allegedly paying bribes to influence oil drilling contracts in Angola.



Ericsson’s sordid affair with DOJ raises questions on DPAs, transparency


A critical examination of Ericsson’s 2019 deferred prosecution agreement and the Department of Justice’s determination the company breached the agreement raises questions regarding the overall lack of accountability in the corruption scheme.



Alleged fraudster cited privacy in duping JPMorgan into $175M merger


Charlie Javice and her startup Frank allegedly convinced the country’s largest bank to pay $175 million for what largely amounted to a list of fake college students. The apparent due diligence failures by JPMorgan Chase offer a cautionary tale to compliance professionals.

Wells Fargo

News Brief

Wells Fargo fined $98M for facilitating sanctions violations in Iran, Syria, Sudan


Wells Fargo will pay nearly $98 million to settle charges a subsidiary facilitated more than $532 million worth of prohibited transactions in violation of sanctions against Iran, Syria, and Sudan.


News Brief

Evoqua Water Technologies to pay $8.5M for alleged revenue inflation


Evoqua Water Technologies Corp. agreed to pay $8.5 million to resolve charges the actions of a former company finance director led the firm to misstate its revenue in filings with the Securities and Exchange Commission.


News Brief

SEC orders Rio Tinto to pay $15M over FCPA violations


U.K.-based mining and minerals company Rio Tinto will pay a $15 million fine to settle charges of violating the Foreign Corrupt Practices Act when it entered into a scheme with a consultant in 2011 to bribe government officials in Guinea.

Google HQ


​Google, Uber CCOs share approaches to data analytics


The chief compliance officers of Google and Uber offer insight into how their data analytics compliance programs have evolved amid enhanced scrutiny on use of technology from the Department of Justice.