- 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 bank examiner and senior manager at the Federal Reserve Bank of Richmond pled guilty to insider trading after allegedly misappropriating confidential information on seven banks to make profitable trades.
New York-based investment firm Drexel Hamilton will pay more than $1.1 million in penalties, with four current and former employees paying fines as well over committing hundreds of violations of rules regarding the sale of municipal bonds.
A publicly traded cryptocurrency mining company will pay $10 million and completely change its business model to one with “lower corruption risk” as part of a settlement over violations of the Foreign Corrupt Practices Act (FCPA), two regulators announced.
