Compliance & Ethics

In an effort to proactively identify and address criminal conduct within the Southern District of New York (SDNY), U.S. Attorney Damian Williams has announced the initiation of the Whistleblower Pilot Program for 2024. The program aims to encourage the early and voluntary disclosure of criminal conduct by individuals involved in certain non-violent offenses. Williams outlined the details of the program and its potential impact on the District's enforcement efforts.

Turkey's competition authority has taken a firm stance against Facebook parent Meta Platforms Inc., announcing a daily fine of 4.8 million lira (approximately $160,000) for Meta's failure to provide adequate documentation in response to a prior investigation.

The Securities and Exchange Commission (SEC) has announced charges against the global software company SAP SE for violating the Foreign Corrupt Practices Act (FCPA) in connection with bribery schemes across multiple countries. The company has agreed to pay nearly $100 million in disgorgement and prejudgment interest to settle the SEC’s charges.

Atlantic Home Health Care LLC (AHH), a home healthcare agency operating in nine states, has agreed to pay $9,990,944 to resolve allegations of violating the False Claims Act. The settlement stems from accusations that AHH submitted false claims to the Energy Employees Occupational Illness Compensation Program (EEOICP), a healthcare initiative administered by the Department of Labor (DOL) for the benefit of Department of Energy employees and contractors with occupational illnesses.

In a significant stride toward combating global corruption, the United States has enacted the Foreign Extortion Prevention Act (FEPA), allowing federal prosecutors to bring criminal charges against foreign government officials soliciting or accepting bribes from U.S. companies. The newly minted law, a component of the National Defense Authorization Act, addresses a longstanding gap in the fight against corruption, as it criminalizes the "demand" side of cross-border corruption, providing a crucial addition to the Foreign Corrupt Practices Act (FCPA).

In a candid interview with the Wall Street Journal's Risk and Compliance Journal, Acting Comptroller of the Currency Michael Hsu delved into the multifaceted landscape of banking regulations, risk management, and the intricate dance between financial stability and technological evolution. The tumultuous year of 2023 witnessed the banking sector thrust into the spotlight, grappling with crises that engulfed Silicon Valley Bank, Signature Bank, and Credit Suisse Group. Against this backdrop, Hsu provided unique insights into the regulatory intricacies shaping the industry and outlined potential strategies for the future:

The Securities and Exchange Commission (SEC) has taken swift action against Miami-based real estate developer Rishi Kapoor, securing an asset freeze and emergency relief in response to an alleged $93 million real estate investment fraud. The SEC has also filed charges against Location Ventures LLC, Urbin LLC, and 20 other entities connected to the fraudulent scheme.