The SEC announced the first FCPA enforcement action in 2022. South Korean telecommunications company, KT Corporation, agreed to pay $6.3 million to settle FCPA violations. As part of the settlement, KT Corp. agreed to pay $3.5 million in civil penalties and $2.8 million in disgorgement. KT Corp. is South Korea’s largest telecommunications company. KT Corp. violated the FCPA’s books, records, and internal accounting control provisions stemming from its South Korea and Vietnam activities. As explained in the SEC’s Order, KT lacked sufficient internal accounting controls over its expenses, including executive bonuses and purchases of gift cards, which resulted in KT Corp. managers and executives generating slush funds for illegal purposes. Additionally, KT Corp. failed to adopt anti-corruption policies and procedures concerning donations, employment candidates, vendors, subcontractors, or third-party agents. As a result, KT Corp. employees could provide improper benefits to government officials and potential government customers.
In this episode, Michael Volkov reviews the KT Corp. settlement.
Day: March 4, 2022
Despite wherever you’re trying to go in life, believe it or not, cultivating healthy relationships is one of the most critical factors in achieving your goals.
Hearing this may have you thinking that you need to focus on other people to build relationships. However, this couldn’t be further from the truth.
A lot of the time, it comes down to us, in that we choose who to be around. The way we attract others comes from within, and in today’s episode, we discuss how you can put yourself in healthier relationships by focusing on yourself!
Listen in at: https://www.jasonmefford.com/jammingwithjason258/.
This week the Compliance Kitchen is looking at sanctions levied on Russia because of its invasion of Ukraine. Today, UK’s second wave of sanctions on Russia.
After a tumultuous and historic week, Brian and Tim gather themselves to discuss the U.S. (and global) response to Russia’s invasion of Ukraine. They start by diving in to the broad, coordinated economic sanctions aimed at debilitating Russia’s financial sector and Putin’s inner circle, debate how well the new measures will work, and contemplate what could be coming next. They next turn to the significant expansion of export controls implicating Russia and discuss the likely impact. Finally, in the Lightning Round, Brian and Tim bid farewell to DOJ’s China Initiative and read between the lines to decipher DOJ’s ongoing priorities.
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EMBARGOED! is not intended and cannot be relied on as legal advice; the content only reflects the thoughts and opinions of its hosts.
***Stay sanctions free.***
As Ukraine hangs on from the Russian invasion, Jay is on assignment so fan fav Kristy Grant-Hart joins this week as a co-host with Tom to look at some of the week’s top compliance and ethics stories from the impact of the Ukrainian crisis in the Ukraine Hangs On edition.
Stories
- What Russia invasion means for companies and compliance. Tom with a series in the FCPA Compliance and Ethics Blog. Matt Kelly in Radical Compliance.
- Dick Cassin says sanctions may lead to more corruption in the FCPA Blog.
- Jaclyn Jaeger looks at supply chain disruption and issues in Compliance Week (sub req’d)
- Matthew Murray asks if Putin invaded Ukraine to advance corruption, in GAB.
- Chasing oligarchs’ money, from the Washington Post.
- The Swiss approach to Ukraine crisis. Mark Pieth in Risk and Compliance Europe.
- Mike Volkov focuses on new and evolving sanctions, in Corruption Crime and Compliance.
- Economic nationalism and corporate governance. Martin Geller, in Harvard Law School Forum on Corporate Governance.
- Illicit finance and High-value art. Sullivan & Cromwell lawyers in Compliance and Enforcement.
- The invasion and cybersecurity. Jonathan Armstrong in Cordery Compliance.
Podcasts and More
- In March on The Compliance Life, I visit with Audrey Harris, Managing Director at AMI, formerly CCO at BHP. In Part 1, she discusses her academic background and early professional career.
- On the FCPA Compliance Report, Tom has a 2-part series with Trade Compliance guru Matt Silverman on the full extent of possible Russia sanctions (Part 1) and the corporate response you need to make (Part 2).
- Tom and Loren Steffy look energy issues and fallout from the Russian invasion in Greetings and Felicitations.
- Tom and Matt Kelly take a deep dive into the compliance weeds about the Russian invasion on Compliance into the Weeds.
- Silvia Surman devotes the entire week to Russian trade sanctions and economic issues in The Compliance Kitchen.
- Tom celebrates Texas Independence Day and the anniversary of the Alamo in a podcast with Don Frazier, Executive Director of the Texas Institute at Schreiner University on The Hill Country Podcast.
Tom Fox is the Voice of Compliance and can be reached at tfox@tfoxlaw.com. Kristy Grant-Hart is Compliance Kristy and can be reached at kgranthart@sparkcompliance.com.
In today’s edition of Daily Compliance News:
- Ex-Nissan exec given suspended sentence in Japan. (NYT)
- CA companies perverting Federal Arbitration Act. (Reuters)
- Is crypto complying with sanctions. (WaPo)
- DOJ accuses Ericsson of violating DPA. (The Guardian)
