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Former Apple CCO Charged with Bribery

By GAN Integrity

Welcome to This Week In Compliance: GAN’s weekly news roundup, where we curate the latest stories on compliance and anti-corruption to keep you informed. This week, a former Apple executive faces corruption charges. Read the full story and more news below:

Top Story

Former Apple Executive Charged with Bribery:

Thomas Moyer, former Chief Compliance Officer and current Head of Global Security at Apple, was charged with bribery on November 23rd. Moyer stands accused of bribing Californian police officers with iPads and other goods in exchange for concealed firearms permits. California's sheriff's office reported that the Apple executive had agreed to give USD 70,000 worth of items disguised as donations to public employees. The former CCO denied all allegations and instead stated that the iPads were donated to an education center that was unrelated to the weapon permits.


DOJ Ends Oversight of Odebrecht:

In 2016 Brazilian construction conglomerate settled a multi-country corruption case with the U.S. Department of Justice (DOJ) and agreed to a supervisory period for compliance oversight for three and a half years. The conglomerate filed for bankruptcy in the U.S. and Brazil in 2019. This week, Odebrecht announced that one of the DOJ's independent compliance monitors had certified the company's compliance program as being designed to prevent FCPA breaches. The monitorship period began in 2017 and was prolonged for another nine months in February because the company had not yet implemented adequate anti-corruption practices. In 2016, Odebrecht and partner company Braskem agreed to pay a fine of USD 3.5 BN for using hundreds of millions of dollars to bribe public officials across Latin America in exchange for contracts for public infrastructure development.

JPMorgan Chase to Pay USD 250M Over Poor Internal Controls:

Investment bank JP Morgan Chase & Co. settled charges over internal control deficiencies for USD 250M with the Office of the Comptroller of the Currency. Among other things, the regulator charged the bank for having inappropriate risk management procedures and lacking a solid structure to prevent conflicts of interest. Regulators also signaled weaknesses in the bank's audit program for fiduciary activities. JPMorgan did not accept or deny the findings and reinstated their commitment to enhancing their internal controls. This settlement comes two months after the bank paid USD 920M for market manipulation.

Regulatory Updates

EU Ombudsman Raises Concerns Over EU Blackrock Contract:

After the world's largest asset manager Blackrock was contracted for a consultation process for the EU's future banking regulations on environmental and social risks, EU Ombudsman Emily O’Reilly urged the Commission to update its guidance on hiring contractors for potential conflicts of interest. O'Reilly stated that since Blackrock's technical brief would eventually be feeding into policy aimed at regulating its area of work, the contracting process should have been scrutinized more. The ombudsman's complaint came after some members of the EU Parliament and an NGO raised concerns about the contracting process.

HRW Publishes Report and Recommendations for RCJ:

Human Rights Watch (HRW) published a report on November 24th investigating the human rights conditions in the supply chains of 15 of the world's largest jewelry companies, most of which are members of the Responsible Jewelry Council. The report finds that some of the serious human rights abuses that continue to take place in the industry have been exacerbated by COVID-19, leaving thousands of miners in producing countries in even more vulnerable conditions. Besides urging regulators to continue to develop more mandatory human rights due diligence laws, such as the EU's Conflict Mineral Law going into force on January 1st, 2021, HRW also provided guidance on strengthening some of the industry's internal standards and recommended stricter compliance with other international human rights instruments, implementation readiness, COVID-19 flexibility, and more transparency related to the standard's auditing requirements.


Former French President Sarkozy Faces Corruption Trial:

After attempts to postpone a court hearing, former French President Nicolas Sarkozy will face trial next Monday, November 30th. Sarkozy, who served as president from 2007 to 2012, faces corruption charges for offering jobs in exchange for insider information on campaign financing. Wiretaps of Sarkozy's conversations revealed that the former president allegedly offered French judge Gilbert Azibert a job in exchange for his help with another public inquiry into suspicions that Sarkozy received illicit funds to finance his 2007 campaign. Both former officials are facing potential jail time of up to 10 years and fines of up to EUR 1M (USD 1.2M).

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