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Friday Roundup

Roundup

Settled, not a victim, and monitor reports. It’s all here in the Friday roundup.

Settled

As highlighted in this prior post, in 2021 Shaquala Williams (a former employee of JPMorgan in New York city) filed a civil complaint in federal court (S.D.N.Y) against JPMorgan in connection with (at least in part) compliance obligations imposed upon JPMorgan in connection with resolution of its 2016 FCPA enforcement action. JPMorgan responded (see here) by filing a motion for summary judgment which was mostly denied by Judge Jed Rakoff who set a trial date for November 2022.

As reported here, the parties have reached an agreement to resolve the matter.

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Deputy Attorney General Monaco Releases A Memo Titled “Further Revisions to Corporate Criminal Enforcement Policies Following Discussions with Corporate Crime Advisory Group”

Monaco

Last week Deputy Attorney General Lisa Monaco issued a 15 page memo to DOJ personnel titled “Further Revisions to Corporate Criminal Enforcement Policies Following Discussions with Corporate Crime Advisory Group.” (See here for Monaco’s related speech and see here for a recent speech by Assistant Attorney General Kenneth Polite which discussed, in part, the memo as well).

A future post will provide analysis and commentary regarding the memo, but first this post summarizes the memo.

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One Big Word Salad

WordSalad

Former DOJ “compliance counsel” Hui Chen (currently a consultant at Ropes & Gray’s Insight Lab) was recently interviewed by Corporate Crime Reporter (CCR) on the state of corporate compliance.

Chen’s responses were generally one big word salad.

In and of itself, who really cares.

However, what makes Chen’s responses ironic is that while serving as DOJ “compliance counsel” she (rightfully) criticized the compliance community for the “lack of precision and intellectual rigor” in much compliance writing and commentary (see here for the prior post).

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Issues To Consider From The Glencore Enforcement Action

Issues

This previous post highlighted the recent net $443 million Foreign Corrupt Practices Act enforcement action against Glencore.

This post highlighted the CFTC’s related enforcement action against the company.

This post discussed how the executive officer certification in the FCPA enforcement action sets up Glencore personnel to fail.

This post continues the analysis by highlighting additional issues to consider from the Glencore FCPA enforcement action.

Timeline

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Glencore Resolves An Approximately $443 Million Net FCPA Enforcement Action

glencore

In mid-2018 Glencore (a commodities company incorporated in the United Kingdom and headquartered in Switzerland disclosed that it was under scrutiny by the DOJ. (See here for the prior post).

Specifically, the company disclosed:

“Glencore Ltd, a subsidiary of Glencore plc, has received a subpoena dated 2 July, 2018 from the US Department of Justice to produce documents and other records with respect to compliance with the Foreign Corrupt Practices Act and United States money laundering statutes.  The requested documents relate to the Glencore Group’s business in Nigeria, the Democratic Republic of Congo and Venezuela from 2007 to present. Glencore is reviewing the subpoena and will provide further information in due course as appropriate.”

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