The Department of Justice and the Securities and Exchange Commission reached a $41 million settlement with GOL Linhas Aéreas Inteligentes S.A. (“GOL”) to resolve criminal and civil foreign bribery charges. GOL entered into a three-year deferred prosecution agreement (“DPA”) with the DOJ in exchange for payment of a $17 million criminal penalty. DOJ credited $1.7 million of that penalty against a $3.4 million fine that GOL agreed to pay law enforcement authorities in Brazil to resolve charges in Brazil. In a separate resolution, GOL agreed to pay the SEC $24.5 million over two years. The SEC’s initial settlement calculation was for $70 million, but it was reduced to $24.5 million based on GOL’s financial condition. Michael Volkov reviews the DOJ and SEC FCPA settlement actions in this episode.
Tag: corruption
Risk is never static but dynamic.
The Goldman Sachs case has proven that playing with fire will always get you burned. Listen in as Tom Fox, and Michael DeBernardis dissect the rights and wrongs of the situation, why probing deeper into red flags is a must, the importance of setting off preventative controls right away, and why companies should publicly show their general policy statement.
▶️ The Goldman Sachs Corruption Case with Tom Fox and Michael DeBernardis
Key points discussed in the episode:
✔️ Tom Fox gives a brief background on the Goldman Sachs case.
✔️ Michael DeBernardis explains the successes and failures in compliance.
✔️ Tom Fox points out the suspicious timing of bond offerings, the significant risk involved, and why organizations should trust but verify, considering the visibility within the organizational structure.
✔️ Michael DeBernardis emphasizes why preventative controls like electronic surveillance should be implemented right away and how the Goldman Sachs case proves that improving your company structure is vital.
✔️ Tom Fox and Michael DeBernardis talk about the Monaco Memo and how the Goldman Sachs case perfectly applies the implementation of clawbacks.
✔️ Michael DeBernardis encourages companies to publish their general policy statement to prevent future problems.
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Do you have a podcast (or do you want to)? Join the only network dedicated to compliance, risk management, and business ethics, the Compliance Podcast Network. For more information, contact Tom Fox at tfox@tfoxlaw.com.
Corporate culture is all the rage now, meaning it is an often used topic to signal commitment, sensitivity to issues of employee concern, and awareness of governance trends. In practice, as we all know, culture is not just about words but about action. As the often repeated phrase goes — talk is cheap. In this Corporate Culture Roundup Episode, Michael Volkov examines some culture-related issues involving: Culture + Action Steps, Civility in the Workplace, and What Happens when HR and Compliance are Disconnected.
In today’s edition of Daily Compliance News:
- Kraken CEO, who attacked his employees, steps down. (NYT)
- Citigroup offers a work-life balance at half pay. (FT)
- Canadian company faces corruption charges under CFPOA. (RCMP Press Release)
- Disgraced Suns owner to sell the team. (Bloomberg)
In today’s edition of Daily Compliance News:
- Morgan Stanley to pay $35MM for mishandling customer data. (Reuters)
- More on the cheating in chess scandal. (FT)
- 47 persons were charged with theft from a child’s food program. (WaPo)
- Former USC Dean pleads guilty to corruption charges. (Channel 7 News)
In today’s edition of Daily Compliance News:
- Queen Elizabeth’s funeral. (All Papers)
- New British PM Chief of Staff witness in a bribery probe. (FT)
- DOJ wants clawbacks. (DOJ Press Release)
- Activity is not productivity. (WSJ)
