FinCen accesses a civil penalty of $450,000 against a former risk officer

Overview On March 4, 2020 issued a settlement agreement with U.S. Bank’s former Chief Operational Risk Officer Michael LaFontaine whereby FinCen fined Mr. LaFontaine $450,000 and banned him from a compliance role for six years. The settlement agreements state the reason for the actions is due to “his failure to prevent violations of the Bank […]

The Walmart FCPA case

In the beginning… The Foreign Corrupt Practices Act (FCPA) was enacted in 1977, applies to companies listed on U.S. stock exchanges and private companies organized under U.S. laws, their shareholders, directors, employees and agents, as well as other individuals who violate the statute while in U.S. territory. The first FCPA case undertaken by the Department […]

DOJ Compliance Program Guidance

Earlier this year the Department of Justice (DoJ) issued two publications for prosecuting attorneys to provide guidance on assessing the effectiveness of corporate compliance programs. The two publications (April 2019 and July of 2019) further develop and update the “Evaluation of Corporate Compliance Programs,” issued by the Criminal Division’s Fraud Section released in February 2017 […]