Subject to Inquiry

Subject to Inquiry

THE LATEST ON GOVERNMENT INQUIRIES AND ENFORCEMENT ACTIONS

Government Investigations and White Collar Litigation Group

Jah Akande

Photo of Jah Akande Jah is a member of the firm’s nationally recognized Government Investigations and White-Collar Litigation team. His practice focuses on counseling and representing corporate and individual clients in regulatory enforcement actions, government investigations, white collar criminal defense matters, and internal investigations. Jah has represented clients in investigations led by the U.S. Department of Justice and other federal and state regulators involving allegations of fraud and regulatory non-compliance. As part of his practice, he has helped clients navigate sensitive internal investigations and federal litigation by addressing complex legal issues, engaging in witness interviews at various levels of the corporate structure, and consulting on compliance and remediation measures.

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Brazilian Airline to Pay Millions in Coordinated Foreign Bribery Resolution

By Benjamin A. O'Neil, Alex J. Brackett, Andrew Thornton-Dibb and Jah Akande on Anti-Bribery and Corruption
On September 15, 2022, GOL Linhas Aéreas Inteligentes S.A. (GOL), Brazil’s second largest domestic airline, resolved long-running parallel investigations by the U.S. Department of Justice (DOJ) and the Securities and Exchange Commission (SEC). The São Paulo-based company, whose shares are traded on the New York Stock Exchange, consented to a cease-and-desist order with the SEC… Continue Reading

New DOJ Guidance on Corporate Criminal Enforcement

By George J. Terwilliger III, John Adams, Benjamin A. O'Neil, John S. Moran, Caroline Schmidt Burton, Jah Akande and Emily Erb Kelley on Enforcement and Prosecution Policy and Trends
RELATED UPDATE: DOJ Announces “Pilot Program Regarding Compensation Incentives and Clawbacks” with Significant Ramifications for Corporations Facing Criminal Investigations (March 6, 2023) On Sept. 15, 2022, U.S. Deputy Attorney General Lisa Monaco announced important guidance and new actions from the U.S. Department of Justice (DOJ or the Department) on corporate criminal enforcement. Her remarks, delivered… Continue Reading

FinCEN Leader’s Remarks Focus on Securing Digital Identity

By Jah Akande, Matthew Orso, Andrew Konia and McGuireWoods LLP on Financial Institution Regulation
On September 7, 2022, Jimmy Kirby, the Acting Deputy Director of the Financial Crimes Enforcement Network (“FinCEN”), gave remarks during the 2022 Federal Identity Forum & Exposition (“FedID”) on the importance of securing digital identity. In his opening comments, Kirby emphasized digital identity as “fundamental to the effectiveness of every financial institution’s AML/CFT program.”… Continue Reading

Department of Justice Criminal Chief Points to Prevention as Key Aspect of Corporate Compliance

By Benjamin A. O'Neil, Jah Akande and Clare E. Reardon on Compliance
The Assistant Attorney General and head of the Department of Justice’s Criminal Division recently sat for an interview with the Wall Street Journal where he provided important insight into the Department’s increased focus on corporate compliance. Drawing on his experience in the U.S. Attorney’s office and as the Chief Compliance Officer at a Fortune 500… Continue Reading

DOJ and SEC Kick Off the Second Quarter with Major FCPA Settlement with International Waste Management Company

By Benjamin A. O'Neil, Alex J. Brackett, Jah Akande and Elissa Baur on Anti-Bribery and Corruption
On April 20, 2022, the U.S. Department of Justice (DOJ) and Securities and Exchange Commission (SEC) separately announced that Stericycle Inc. (Stericycle), an international waste management company headquartered in Lake Forest, Illinois, has agreed to pay more than $84 million to resolve parallel investigations by authorities in the United States and Brazil. The investigation is… Continue Reading

First FCPA Settlement of 2022 – Enforcement on the Horizon

By Benjamin A. O'Neil, Matthew Orso, Molly White, Jah Akande and McGuireWoods LLP on Enforcement and Prosecution Policy and Trends, Fraud, Deception and False Claims
On February 17, 2022, the Securities and Exchange Commission (SEC) announced the first Foreign Corrupt Practices Act (FCPA) settlement of the year. Seoul-based KT Corporation (KT Corp.), South Korea’s largest telecommunications operator, will pay $6.3 million to resolve charges that it violated the FCPA by providing improper payments for the benefit of government officials in… Continue Reading

FinCEN Director Blanco Comments on Section 314(b)’s New Guidance

By Patrick Rowan, Matthew Orso, Jeffrey M. Hanna and Jah Akande on Financial Institution Regulation
On December 10, 2020, FinCEN Director Kenneth Blanco delivered prepared remarks at the ABA’s annual Financial Crimes Enforcement Conference. At the outset, Director Blanco addressed the importance of U.S. national security amidst the unprecedented environment created by the COVID-19 pandemic. In his remarks, Director Blanco announced “important guidance” and “much needed clarity” concerning FinCEN’s voluntary… Continue Reading

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