Internal Investigations


News Brief

PCAOB dings MaloneBailey $400K over ‘pervasive’ quality control violations


MaloneBailey agreed to pay a $400,000 fine to settle allegations levied by the Public Company Accounting Oversight Board (PCAOB) over “pervasive” quality control violations.


News Brief

Flex says no action by OFAC into possible sanctions violations


Flex disclosed in a public filing the Office of Foreign Assets Control is taking no action into potential sanctions violations the global manufacturer voluntarily self-disclosed in 2019.


News Brief

DOJ orders Evoqua to pay $8.5M over admitted securities fraud


Evoqua Water Technologies agreed to pay $8.5 million as part of a nonprosecution agreement with the Department of Justice to settle admitted criminal charges related to fraudulent revenue recognition.


News Brief

Insight Global to pay $2.7M over lax security on contact tracing data


Atlanta-based staffing agency In­­­­­­sight Global agreed to pay $2.7 million to settle alleged False Claims Act violations for failing to provide adequate cybersecurity on Covid-19 contract tracing data.

Pav Gill 3x2


Wirecard whistleblower laments EU speak-up protection inconsistencies


The European Union’s strong stance on whistleblower protection has been undermined by member states’ wildly different approaches to punishing organizations that fail to safeguard people who raise concerns, says Wirecard whistleblower Pav Gill.

CW2024 BYOD panel


CW2024 panelists discuss BYOD at center of off-channel comms debate


The Department of Justice’s renewed scrutiny toward a corporation’s approach to the use of personal devices strengthens the case for companies to get away from bring your own device, a panelist at Compliance Week’s 2024 National Conference argued.

ADM sign

News Brief

ADM CFO to depart amid accounting probes


Food processing company ADM announced Chief Financial Officer Vikram Luthar, who was placed on administrative leave in January amid a probe into the company’s accounting practices, will resign.


News Brief

Change Healthcare cyberattack updates detail massive impact, costs


The massive cyberattack on Change Healthcare has potentially compromised the personal and protected health information of an untold number of Americans, according to parent company UnitedHealth Group.



June 11 | Compliance programs under scrutiny

2024-04-21T20:37:00+01:00Provided by

Explore government expectations for compliance programs and how companies facing regulatory scrutiny design and implement programs to position themselves for the best possible outcome.


News Brief

Proterial Cable America earns DOJ declination in apparent fraud case


Proterial Cable America received a declination notice from the Department of Justice related to its voluntary self-disclosure and remediation of apparent fraud committed by its employees.



CW2024 keynote tackles fundamentals of fraud detection


“If you want to start to know who’s lying to you, all you got to do is pay attention differently,” advised body language expert Traci Brown during her opening keynote at Compliance Week’s 2024 National Conference.


News Brief

​Chemours: DOJ, SEC probing exec accounting misconduct


Chemours disclosed it received requests for information from the Department of Justice and Securities and Exchange Commission regarding findings from an internal review into alleged accounting misconduct by several of its top executives.


News Brief

Equinix probing short seller accusations amid DOJ scrutiny


Data center owner Equinix disclosed it launched an independent investigation to review matters referenced in a recent short seller report that also caught the attention of the Department of Justice.

Epstein case study cover 3x2


Chapter 4: Investigations into misconduct: What banks can do


Both JPMorgan Chase and Deutsche Bank retained their respective Jeffrey Epstein relationships for too long. Yet, there is a case to be made for why exiting a high-risk relationship too soon can become an inverse form of recklessness.

Epstein case study cover 3x2


Chapter 3: Egregious failures: Customer due diligence and transaction monitoring


Why did JPMorgan Chase retain Jeffrey Epstein for more than a dozen years? How did the relationship persist despite glaring red flags? The “why” is straightforward; the “how” is more complicated.

Epstein case study cover 3x2


Chapter 2: KYC shortfalls: JPMorgan and Deutsche Bank’s onboarding of Epstein


Jeffrey Epstein’s designation as a high-risk client should have subjected him to enhanced due diligence that never appeared to occur, most notably at Deutsche Bank. Instead, Epstein was allowed to continue his misconduct despite numerous red flags.

Epstein case study cover 3x2


Chapter 1: Compliance v. complicity: The ‘underbelly’ of bank culture


Why were decisions made the way they were at the banks that serviced Jeffrey Epstein? Evidence points to a cultural tension: a tug-of-war between the allure of profit and the drag of compliance, with the former having all the pulling power.

EFG International

News Brief

EFG International settles Cuba, blocked persons U.S. sanctions case


Swiss-based global private banking group EFG International agreed to pay more than $3.7 million as part of a settlement with the Office of Foreign Assets Control addressing apparent violations of U.S. sanctions against Cuba and two blocked individuals.


News Brief

DOJ joins SEC in probing ADM accounting practices


ADM disclosed the Department of Justice joined the Securities and Exchange Commission in probing the food processing company’s accounting practices.


News Brief

Chemours says probe found accounting misconduct by execs


Chemours said an internal review into the actions of senior managers alleged to have engaged in accounting misconduct uncovered violations of the chemicals company’s code of ethics regarding the promotion of full, fair, accurate, timely, and understandable disclosure.

Andrew McBride


CW National 2024 preview: Former Albemarle CCO on FCPA case lessons


Andrew McBride, former chief risk and compliance officer at chemical company Albemarle Corp., joins the Compliance Week podcast with Aaron Nicodemus to preview his session at CW’s National Conference in Washington, D.C.

Oil barrels

News Brief

Gunvor to pay $661M to settle FCPA violations in Ecuador


Swiss-based oil trader Gunvor will pay more than $661 million as part of a plea agreement with the Department of Justice to resolve violations of the Foreign Corrupt Practices Act involving a long-running scheme to bribe officials in Ecuador to secure oil contracts.


News Brief

Chemours places senior execs on leave over accounting review


Chemours announced it placed its chief executive officer, chief financial officer, and principal accounting officer on leave pending completion of an internal review into potential material weaknesses in its internal control over financial reporting.

ADM office

News Brief

ADM delays annual report filing amid ICFR assessment


ADM disclosed it will be late in filing its annual report for 2023 as it continues to investigate potential accounting improprieties regarding its nutrition reporting segment.

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.