VIEWS: 12 PAGES: 130 POSTED ON: 6/5/2012
Organization U.S. Atty's Office ABB Ltd. USDOJ - Criminal Division - Fraud Section AB Volvo USDOJ - Criminal Division - Fraud Section ABT Associates Massachusetts Adelphia Communications New York - Southern District Advanced Cosmetic Research Labs AEP Energy Services Ohio - Southern District Aetna Massachusetts AGA Medical USDOJ - Criminal Division - Fraud Section AGCO Corporation USDOJ - Criminal Division - Fraud Section Aibel Group USDOJ - Criminal Division - Fraud Section Akzo Nobel USDOJ - Criminal Division - Fraud Section Alabama Contract Sales Alabama - Northern District Alcatel-Lucent USDOJ, Criminal Division, Fraud Section Alliance One USDOJ - Criminal Division - Fraud Section American Express Bank Int'l USDOJ - Criminal Division American Int'l Group (AIG-FP PAGIC Equity Holding Company Pennsylvania - Western District; & AIG Financial Products Corp.) [3 Indiana - Southern District coordinated agreements] American Int'l Group USDOJ - Criminal Division - Fraud Section American Italian Pasta Company Missouri - Western District AmSouth Bancorp Mississippi - Southern District AOL Virginia - Eastern District Appalachian Oil Virginia - Western District Armour of America California - Central District Arthur Andersen Connecticut Aurora Foods New York - Southern District Baker Hughes USDOJ - Criminal Division - Fraud Section Banco Popular De Puerto Rico Puerto Rico Bank of New York New York - Southern District BankAtlantic Florida - Southern District USDOJ - Criminal Division - Asset Forfeiture and Money Barclays Bank Laundering Section BAWAG P.S.K. (Bank owned by Austrian New York - Southern District Trade Unions Association) Baystar Capital Management LLC California - Northern District BDO Seidman Illinois - Southern District Beazer Homes USA, Inc. North Carolina - Western District Biomet New Jersey Biovail Pharmaceuticals, Inc & Biovail Massachusetts Corporation BL Trading Massachusetts Blue Cross Blue Shield of Rhode Island Rhode Island Boeing Co. California - Central District Bristol-Myers Squibb New Jersey British Petroleum (BP) USDOJ - Criminal Division - Fraud Section Canadian Imperial Bank of Commerce USDOJ - Enron Task Force Ceramic Protection Corporation of Delaware America Chevron New York - Southern District CNH Italia USDOJ - Criminal Division - Fraud Section CNH France USDOJ - Criminal Division - Fraud Section Collins & Aikman Corp. New York - Southern District Columbia Farms, Inc. South Carolina Computer Associates New York - Eastern District ConAgra Poultry Co. Coopers & Lybrand Cosmetics Laboratories of America California - Central District Credit Lyonnais California - Central District Credit Suisse AG USDOJ - Criminal Division CVS/Pharmacy California - Central District Daimler AG USDOJ - Criminal Division - Fraud Section DaimlerCrysler China USDOJ - Criminal Division - Fraud Section DePuy Orthopaedics New Jersey Deutsche Bank AG New York - Southern District Doyon Drilling, Inc. Alaska Edward D. Jones Missouri - Eastern District Elan Corp. Massachusetts El Paso New York - Southern District Electronic Clearing House New York - Southern District Endocare California - Central District English Construction Co. Virginia - Western District ESI Entertainment Systems New York - Southern District Exactech New Jersey Express Scripts Inc. Massachusetts Facility Group Mississippi - Northern District Faro Technologies USDOJ - Criminal Division FHC Delaware, Inc. (formerly Fine Host New York - Southern District Corp.) Fiat S.p.A. USDOJ - Criminal Division - Fraud Section FirstEnergy Nuclear Operating Co. Ohio - Northern District Fisher Sand & Gravel North Dakota Flowserve USDOJ - Criminal Division - Fraud Section Forest Laboratories Massachusetts Friedman's Inc. New York - Eastern District Frosty Treats, Inc. Missouri - Western District GE USDOJ - Criminal Division - Fraud Section General Re Corp. USDOJ - Criminal Division - Fraud Section German Bank HVB New York - Southern District GlaxoSmithKline Massachusetts Halliburton Company USDOJ - Criminal Division - Fraud Section HealthSouth Corp. Alabama - Northern District Helmerich & Payne USDOJ - Criminal Division - Fraud Section Hitachi Corp. USDOJ - Antitrust Division Holy Spirit Association – not available - California - Northern District sealed by agreement between parties HSBC New York - Southern District IFCO Systems New York - Northern District IMC Potash New Mexico Ingersoll Rand USDOJ - Criminal Division - Fraud Section InterMune California - Northern District InVision USDOJ - Criminal Division - Fraud Section ITT USDOJ - Assistant Attorney General, National Security Division Ivenco USDOJ - Criminal Division - Fraud Section Jackson Country Club Mississippi - Southern District Jazz Pharmaceuticals New York - Eastern District JB Oxford Holdings, Inc. (formerly RKS California - Central District Financial Group, Inc.) Jenkins Gilchrist New York - Southern District John Hancock Mutual Life Massachusetts Kos Pharmaceuticals USDOJ - Criminal Division - Fraud Section KPMG New York - Southern District Lawson Products, Inc. Illinois - Northern District Lazard Freres Massachusetts Levlad LLC California - Central District USDOJ - Criminal Division - Asset Forfeiture and Money Lloyds TSB Bank plc Laundering Section Lucent Technologies, Inc. USDOJ - Criminal Division - Fraud Section Maximus District of Columbia MCI New York - Southern District McSha Properties Oklahoma - Western District Medicis Kansas Mellon Bank, N. A. Pennsylvania - Western District Merrill Lynch USDOJ - Enron Task Force Merrill Lynch Massachusetts Micrus Corp. USDOJ - Criminal Division - Fraud Section Milberg California - Central District Mirant Energy Trading USDOJ - Criminal Division - Fraud Section Monford Food Distribution Co. Monsanto USDOJ - Criminal Division - Fraud Section MRA Holdings, LLC Florida - Northern District National Compressor NEC USDOJ - Antitrust Division NETeller PLC New York - Southern District NetVersant-Atlanta, Inc. & NetVersant USDOJ - Antitrust Division Solutions, Inc. NeuroMetrix, Inc. Massachusetts Newsday, Inc. and Hoy Publications LLC New York - Eastern District New York Racing Ass'n New York - Eastern District Noble Corp. USDOJ - Criminal Division - Fraud Section Novo Nordisk A/S USDOJ - Criminal Division - Fraud Section Omega Advisors USDOJ - Criminal Division - Fraud Section Operations Management International Connecticut Optimal Group New York - Southern District Ortho-McNeil-Janssen Pharmaceuticals, Massachusetts Inc. Orthoscript, Inc. Georgia - Northern District Panalpina World Transport USDOJ - Criminal Division - Fraud Section Paradigm B.V. USDOJ - Criminal Division - Fraud Section Parkway Village New York - Eastern District PartyGaming Plc New York - Southern District Pasha Forwarders USDOJ - Antitrust Division Penn Traffic Company New York - Northern District Petrocelli Electric Co. New York - Southern District Pfizer Massachusetts Pharmacia & Upjohn Massachusetts Pilgrim's Pride, Inc. Texas - Eastern District PNC Financial Pennsylvania - Western District PPG Industries District of Columbia Prudential Equity Group Massachusetts Prudential Securities New York - Southern District Purdue Pharma Virginia - Western District Quest Diagnortics, Inc. (& Nichols New York - Eastern District Institute Diagnostics) RAE Systems California - Northern District Reliant Energy Services California - Northern District Republic Services, Inc. Texas - Southern District RFK Institute California - Central District Roger Williams Medical Center Rhode Island Roman Catholic Archbishop of Boston Massachusetts Royal Ahold New York - Southern District Salomon Brothers SB Pharmco Puerto Rico, Inc. (see GSK) Massachusetts Schering Plough Massachusetts Schiavone Construction Co. LLC New York - Eastern District Schnitzer Steel USDOJ - Criminal Division - Fraud Section Sears Illinois - Southern District Sequa Serono Massachusetts Shell Nigeria Exploration and Production USDOJ - Criminal Division - Fraud Section Co., Ltd. Shoppers Food Warehouse Corp. Maryland Sigue USDOJ - Criminal Division Sirchie Acquisition Co. North Carolina - Eastern District Smith & Nephew PLC New Jersey Snaprogetti Netherlands USDOJ - Criminal Division - Fraud Section Spectranetics Corporation Colorado Sportingbet New York - Southern District Statoil, ASA New York - Southern District Stryker Orthopedics New Jersey Swift Beef Iowa - Northern District Symbol Technologies New York - Eastern District Technip S.A. USDOJ - Criminal Division - Fraud Section Textron USDOJ - Criminal Division - Fraud Section Tidewater Marine International USDOJ - Criminal Division - Fraud Section Tommy Hilfiger New York - Southern District Trace America Transocean USDOJ - Criminal Division - Fraud Section TriCare-Orthoscript USDOJ Tyson Foods USDOJ - Criminal Division - Fraud Section UBS AG Florida - Southern District Union Bank of California USDOJ - Criminal Division - Fraud Section United Bank for Africa New York - Southern District Universal Corp. USDOJ - Criminal Division - Fraud Section University of Medicine and Dentistry of New Jersey New Jersey Unum Group California - Southern District UTStarcom, Inc. USDOJ - Criminal Division - Fraud Section Vetco USDOJ - Criminal Division - Fraud Section Wachovia Florida - Southern District Wellcare Health Plans, Inc. Florida - Middle District WesternGeco LLC (subsidiary of Texas Schlumberger Seismic, Inc.) Westinghouse Air Brake Technologies USDOJ - Criminal Division - Fraud Section Corp. Whitehall Jewelers, Inc. New York - Eastern District Willbros USDOJ - Criminal Division - Fraud Section Williams Power Co. California - Northern District Wright Medical Technology, Inc. New Jersey York International Corp. USDOJ - Criminal Division - Fraud Section Zimmer Holdings Inc. New Jersey NP U.S. Atty's Office 2 Date or Crime DP Oct-10 DP FCPA; wire fraud Wire fraud; falsification of books and Mar-08 DP records Jan-07 DP False Claims May-05 NP Sec. fraud Jan-05 DP Fraud (commodities reports) Aug-93 NP Fraud (pension funds) violation of the Foreign Corrupt Jun-08 DP Practices Act Wire fraud; falsification of books and Sep-09 DP records in violation of FCPA Feb-07 DP FCPA Dec-07 NP FCPA Apr-07 DP Federal Program Fraud Dec-10 DP FCPA Aug-10 DP FCPA Failure to maintain an anti-money Aug-07 DP laundering compliance program Violations of antifraud provisions and aiding and abetting violations of USDOJ - Criminal Division - Fraud Section Nov-04 DP reporting and record keeping provisions of the federal securities laws Misstatements in periodic financial Feb-06 NP reports Mail and wire fraud; accounting improprieties; misrepresentations and Sep-08 NP false statements to Dep't of Commerce related to antidumping Oct-04 DP Bank Secrecy Act USDOJ - Criminal Division Dec-04 DP Sec. fraud Jan-07 DP Wire fraud Arms Export Control Act and related Dec-93 DP regs / other federal statutes Apr-96 DP Accounting fraud Jan-01 NP Accounting fraud Apr-07 DP FCPA Jan-03 DP Failure to file SARS Money laundering, unlicensed money New York - Eastern District Nov-05 NP transfers; no anti-money laundering program Bank Secrecy Act, failure to maintain Mar-06 DP eff. anti-money laundering program Knowing and willful violations of International Emergency Economic Aug-10 DP Powers Act; violations of Trading with the Enemy Act Oct-06 NP Banking and sec. fraud Mar-11 DP Wire fraud USDOJ - Criminal Division Apr-02 DP Accounting fraud Fraudulent mortgage practices; USDOJ - Civil Division (separate agreement) Jul-09 DP fraudulent accounting practices Anti-Kickback Statute (payments to Sep-07 DP doctors) Payments to customers including but not limited to physicians to induce May-08 NP recommendations, prescriptions and purchases of a Biovail product Wire fraud; sale and receipt of stolen Dec-10 DP property after transportation in interstate commerce USDOJ - Criminal Division - Public Integrity Section Dec-07 DP Mail fraud Federal procurement fraud, conflict of Virginia - Eastern District Jun-06 NP interest, use of competitor's information Jun-05 DP Sec. fraud Mail and wire fraud, Commodities Oct-07 DP Exchange Act Aided and abetted accounting fraud (by Dec-03 DP Enron) Jan-10 DP False statement Bribery (for purchases of Iraqi oil under Nov-07 NP Oil-for-Food program) Conspiracy to commit wire fraud and Dec-08 DP falsification of business records under FCPA Conspiracy to commit wire fraud and Dec-08 DP falsification of business records under FCPA Mar-07 NP Tax Fraud hiring and continuing to employ Nov-09 DP unauthorized workers; making false statements Sep-04 DP Sec. fraud; obstruction Obtaining confidential bid info during K Sep-96 NP selection; lying to grand jury Jun-10 NP Failure to supervise and cotrol lending in connection with certain corporate Jun-99 NP acquisitions, and misconduct in relation to same transactions (Separate investigation underway by French gov't) Knowing and willful violations of International Emergency Economic Dec-08 DP Powers Act prohibiting unauthorized export of services to Iran Failure to take the proper steps to Nevada Oct-10 NP prevent the sale of PSE for illegal purposes Mar-10 DP FCPA Mar-10 DP FCPA Sep-07 DP Anti-Kickback Law USDOJ - Tax Division Dec-10 NP Tax evasion CERCLA and Clean Water Act violations: neglegent discharge of oil USDOJ - Environmental Crimes Section Apr-98 DP and hazardous substances upon U.S. shorelines Dec-04 DP Sec. fraud Inappropriate off-label promotion of Dec-10 NP drug Feb-07 NP Anti-Kickback Law Illegal transactions (processing Mar-07 NP payments for online gambling) Criminal violations by employees in Jul-06 NP relation to disclosures to investors Mar-07 DP False Statements charges related to illegal gambling, Jun-08 DP both internationally and interstate Dec-10 DP Anti-Kickback Law Illegal distribution of human growth Sep-07 NP hormone Aug-10 NP FCPA violations: Improper "referral fees" to agents of state-owned Chinese Jun-08 NP entities and accompanying accounting improprieties Nov-08 NP Invoice fraud Conspiracy to commit wire fraud and Dec-08 DP falsification of business records under FCPA Environmental crimes, false statements Jan-06 DP by employees USDOJ - Tax Division Apr-09 DP Tax fraud Conspiracy to commit wire fraud and Feb-08 DP falsification of business records under FCPA USDOJ - Civil Division - Office of Consumer Illegal promotion of non-approved Sep-10 NP Litigation drugs, False Claims Act Securities fraud; consp to commit bank Nov-05 NP and wire fraud Sep-07 NP Obstruction of mail Dec-04 NP FCPA Securities fraud related to Jan-10 NP misstatements of AIG's general insurance underwriting loss reserves Feb-06 DP Conspiracy to defraud IRS USDOJ - Criminal Division Oct-10 NP False claims FCPA violations: corrupt payments and improper disclosures, accounting, Feb-09 NP internal controls and record-keeping associated with the foregoing May-06 NP Accounting fraud and sec. fraud Improper payments to officials of Jul-09 NP foreign governments in violation of FCPA Jan-06 NP Antitrust violations Feb-07 NP Dec-01 NP Hiring and employment of illegal alien workers; document and identity fraud; Dec-08 NP impeding the functions of the SSA and IRS; FLSA violations Sep-02 NP Conspiracy to commit wire fraud and Oct-07 DP falsification of business records under FCPA Intent to defraud / mislead causing drug Oct-06 DP to be misbranded Dec-04 DP Foreign Corrupt Practices Act (“FCPA”) Virginia - Western District Mar-07 DP Arms Export Control Act violations Conspiracy to commit wire fraud and Dec-08 DP falsification of business records under FCPA hiring and continuing to employ illegal Feb-08 DP aliens; providing false identification information to the SSA Jul-07 NP Fraudulent drug marketing Securities fraud: failure to disclose to investing public activities and beneficial Feb-00 NP ownership interest of a consultant (Irving Knott) Mar-07 NP Tax fraud Mar-94 NP Mail fraud Louisiana - Middle District Dec-10 DP Anti-Kickback Statute Tax fraud, conspiracy to defraud IRS; Aug-05 DP tax evasion Aug-08 DP Mail fraud Oct-95 NP Wire fraud Oct-08 NP Knowing and willful violations of International Emergency Economic Jan-09 DP Powers Act prohibiting unauthorized export of services to Iran Nov-07 NP FCPA Jul-07 DP Health Care Fraud Sep-05 NP Sec. fraud Jan-09 NP Oct-06 NP Theft of gov't property, theft of mail Aug-06 NP matter, conspiracy Sep-03 NP False statements, aided/abetted Enron Oct-95 NP N/A. Feb-05 NP FCPA conspiracy; mail fraud; money Jun-08 NP laundering; obstruction of justice; criminal forfeiture California - Northern District Jul-07 DP False Commodities reporting Jan-05 DP FCPA Sep-06 DP Failing to label sexually explicit material Jan-06 NP Antitrust violations Conspiracy to conduct an illegal Jul-07 DP gambling business Fraudulent and anti-competitive Mar-07 NP conduct in relation to the federal E-Rate program Violations of the Medicare Anti- Jan-09 NP Kickback Act Fraud - reporting inflated circulation Dec-07 numbers to advertisers through reports to trade organization Dec-03 DP Conspiracy to defraud; tax fraud Nov-10 NP FCPA Conspiracy to commit wire fraud and May-09 DP falsification of business records in violation of FCPA New York - Southern District Jun-07 NP FCPA Jun-05 DP Clean Water Act Unlawful Internet Gambling Oct-09 NP Enforcement Act Apr-10 NP Drug misbranding Jun-05 DP Medicare fraud Nov-10 DP FCPA Sep-07 NP FCPA CERCLA violation, failure to report Aug-08 NP asbestos Offering internet gambling services and masked payment procedures to US Apr-09 NP residents in knowing violation of certain U.S. criminal laws Sep-06 NP Antitrust violations Securities fraud related to diclosures to Oct-08 NP SEC and investors Jul-09 NP Illegal payments and gifts Mar-07 NP Anti-Kickback Law Mar-07 DP Anti-Kickback Law Alien smuggling crimes and unlawful Dec-09 NP employment of aliens USDOJ - Criminal Division - Fraud Section Jun-03 DP Sec. fraud Violation of International Emergency Dec-10 NP Economic Powers Act Aug-08 NP Deceptive trading of mutual funds Fraud in sale of limited partnership Oct-94 DP interests May-07 NP Misbranding Felony misbranding in violation of Food, Apr-09 DP Drug and Cosmetic Act Dec-10 NP FCPA Commodity price manipulation and wire Mar-07 DP fraud Immigration and fraud violations; Oct-08 NP conspiracy to commit mail fraud and encourage unlawful immigration Nov-08 NP Jan-06 DP Public corruption Nov-05 NP accounting fraud; false statements in Sep-06 NP SEC filings May-92 NP USDOJ - Criminal Division Oct-10 NP Aug-06 NP False statements to FDA Nov-10 NP Building construction fraud bribery under FCPA; wire fraud; false 2006-10 DP entries in books and records of public corporation Apr-01 DP Mail fraud Jun-93 NP Introduction of adulterated medical Oct-05 NP devices to interstate commerce Nov-11 DP FCPA Sep-10 DP Bribery Failure to maintain adequate anti- Jan-08 DP money laundering program Violations of Denial Order against Feb-10 DP president of predecessor-in-interest Sep-07 DP Anti-Kickback Law Jul-10 DP FCPA bribery Conspiracy to commit mail and wire USDOJ - Office of Consumer Litigation Dec-09 NP fraud; import violations; violations of Food, Drug and Cosmetic Act Sep-10 NP Internet gambling violations USDOJ - Criminal Division - Fraud Section Oct-06 DP FCPA Oct-05 NP Anti-Kickback Law Oct-02 NP Jun-04 NP Accounting fraud Jun-10 DP FCPA bribery Aug-07 NP FCPA Nov-10 DP FCPA bribery Aug-05 NP mail fraud; wire fraud Nov-10 DP FCPA bribery Jun-05 NP False claims for Medicare payment Feb-11 DP FCPA Feb-09 DP Conspiracy to commit tax fraud Failure to establish adequate anti- Sep-07 DP money laundering program Jul-07 NP Obstruction of justice Improper payments to officials of Virginia - Eastern District Aug-10 NP foreign governments in violation of FCPA Dec-05 DP Health care fraud Jun-08 NP Dec-09 NP Violations of FCPA Feb-07 DP FCPA USDOJ - Criminal Division - Asset Forfeiture and Failure to maintain adequate anti- Mar-10 DP Money Laundering Section money laundering program May-09 DP Conspiracy to commit health care fraud Jun-06 DP Immigration (visa) fraud Feb-08 NP bribery in violation of FCPA Sep-04 NP Bank fraud May-08 DP FCPA Feb-06 DP Fraudulent commodities reports Oct-10 DP Anti-Kickback Statute Oct-07 DP FCPA Sep-07 DP Anti-Kickback Law Indep. Monitor Compliance Program Required Req. Yes - Compliance and ethics program designed to detect and prevent violations of the FCPA and other applicable anti-corruption laws will No continue and will implement certification systems for senior managers to ensure they are knowledgable Yes -- system of internal accounting controls, implementation of No compliance code; assignment of senior corporate officials to oversight Yes Yes No No No No No No Yes - system of internal accounting controls; implementation of Yes compliance code Yes - Implement compliance and ethics program; enhance compliance No policies and procedures Yes - implementation of compliance and ethics program; governance No, but Company must comply with reports from Compliance Counsel restructuring to ensure compliance No Yes; compliance code, disciplinary procedures, training No Yes, training, 2 year ban on participation in federal grant programs Yes - DOJ chooses from Yes - retain compliance and ethics program; compliance code; among 3 French disciplinary procedures; system of internal accounting controls nationals chosen by company Yes, proposed by Yes - continue compliance program; review system of internal accounting Company and controls; rigorous compliance code chosen by DOJ No Remedial measures designed to fully comply with the Bank Secrecy Act Yes, chosen by DOJ, SEC, and Yes - series of reforms addresing the inegrity of client and third-party AIG as part of transactions; establishment of transaction review committee separate SEC agreement Yes, to conduct a comprehensive Yes - Remediation plan re: controls over financial reporting; training and examination and education program review No No No No Yes: 1 yr, agreed Yes: new policies, including future reporting to the DOJ of any upon by DOJ, substantial, credible evidence of new federal crimes SEC, and AOL No Yes, retaining compliance officer, training, supervision, disclosure program No Yes No No Yes: outside Yes: new policies; confidential reporting by employees consultant Yes (Stephen Fishbein, Yes Shearman & Sterling LLP) No No Yes. Yes: new policies, training; new management structure; reporting system No No Yes; compliance procedures revamped, provide training for compliance No officers and employees; must provide notification of adoption of SWIFT system and compliance with the agreement. No No No No No Yes: auditing; data collection No No Yes; compliance department expanded, policy review and needs Yes assessment in process; Corporate Integrity Agreement with HHS-OIG No No Yes; establishment of Compliance officer; establish clear identity of No vendors and transactions Yes, will strengthen compliance program to satisfy “in all respects” the Yes U.S. Sentencing Guidelines requirements Yes: Special Compliance Yes: training; discipline; prohibiting retaliation; hot line created; auditing of Officer appointed compliance program created; Interim Agreement with the Air Force already under providing for compliance, an independent monitor, and auditing of Interim compliance Agreement with Air Force Yes Yes: policy changes; data collection; info on website Yes Yes Yes. Yes: auditing; policy changes; data collection; confidential reporting No No No Yes Yes - independent Yes - Compliance and ethics program designed to detect and prevent review and audit violations of the FCPA and other applicable anti-corruption laws of remedial measures Yes - independent Yes - Compliance and ethics program designed to detect and prevent review and audit violations of the FCPA and other applicable anti-corruption laws of remedial measures No No Yes: Annual Yes - designation of compliance officer; establishment of review and self- review by outside reporting procedures; use of SSA's Social Security Number Verification compliance Service; internal training program; agreements with subcontractors counsel Yes: auditing; policy changes; data collection; confidential and public Yes. reporting Yes. No No Yes - Training, revision of certain policies, maintenance of electronic No records Yes - compliance and ethics program that in part protects employees who No wish to report violations, install Compliance Officer Yes; three years; Yes; complicance and ethics program; system of financial and accounting proposed by procedures, including system of internal controls Company and approved by DOJ Yes, independent Yes; enhanced compliance program, independent compliance officer, compliance other remedial measures officer Yes, appoint Compliance Officer as member of Management Board, Yes annual needs assessment Yes, appointed Yes, compliance and ethics program, training, new corporate governance by USAO committees Yes, both independent Yes - Environmental compliance program to include: appointment of a consultant and designated responsible compliance officer; development of written work independent practice standards; training; and quaterly reporting to gov't. auditor Yes: new policies, training, compliance program; new executive No committee Yes; must institute procedures and reviews to prevent future misconduct; submit reports to OIG-HHS No No No No No No No No Yes Yes -- specifics unknown as Citadel Controls Report not attached one compliance code, separate compliance officer; trainining; hotlines Yes, not less than Yes;year No Yes, including new training program and records keeping Yes - Review/modification of internal controls, policies and procedures No related to financial accounting and anti-corruption No No Yes - independent Yes - Compliance and ethics program designed to detect and prevent review and audit violations of the FCPA and other applicable anti-corruption laws of remedial measures No No Yes - Designate Compliance Officer to oversee implementation of Code No of Ethics, including periodic audits and duty to report quarterly to both the Board of Directors and the gov't. Yes -- system of internal accounting controls, implementation of No. compliance code; senior corporate official assigned to oversight; reporting system; disciplinary procedures Yes? (audit committee of Yes; have number of independent directors required under NYSE rules; which majority of creation of audit committee, nomination committee and compensation directors must be committee independent) Yes: outside Yes - company agrees to integrate InVision business into their existing independent FCPA compliance program; retain independent consultant consultant Yes - Company agrees to maintain redidiation measures already No implemented Yes: compliance program as per U.S. Sentencing Guidelines; policy No changes; permanent restrictions on banking practices No None stated No No Yes: Governance Consultant as Yes: actions taken or agreed to pursuant to SEC settlement incorporated required by SEC in agreement consent decree Yes - strengthening of compliance, bookkeeping and internal controls No standards and procedures; periodic reporting to USDOJ No Yes Yes - independent auditor to conduct I-9 Yes - Adoption and maintenance of a comprehensive, risk-based audits annually; Compliance Program; designation of full-time Compliance Officer; semi-annual establishment of procedures and an internal training program reports by outside compliance counsel Yes (Jeffrey M. Kaplan) – Yes, compliance and ethics program, internal accounting controls, retained as an compliance code, training, certifications outside consultant No. No. Yes. Yes: policy changes Yes (Not Yet Not stated Named) Yes - independent Yes - Compliance and ethics program designed to detect and prevent review and audit violations of the FCPA and other applicable anti-corruption laws of remedial measures Yes; implementation of "best practices" as to completion of I-9 forms and No. social security number verification under IMAGE No Yes, Corporate Integrity Agreement with HHS incorporated Yes - implementation of recommendations of independent expert; Yes executive certifications of progress No No; its offices “have already been or will soon be closed” No No No No Yes: policy changes; confidential reporting; compliance program as per Yes. U.S. Sentencing Guidelines Yes - designed prevent violations of federal and state anti-corruption No laws, including those by affiliates and subsidiaries No No Yes - independent consultant to review incoming Yes - Company agrees to undertake the further work necessary to payment enhance and optimixe its sanctions compliance programs. messages processed between 2002-07 No Yes; internal accounting controls, compliance code, training No Yes, revise program in accord with U.S. Sentencing Guidelines Yes: compliance program as part of 2004 settlement with Okla. No prosecutors and civil settlements Yes: compliance and ethics program that satisfies U.S. Sentencing Yes. Guidelines; new training; auditing Yes: policy changes; confidential reporting; creation of a special structure Yes. products committee to review transactions No Those already enacted by company; injunctive policy changes Yes. No Yes; implementation of "best practices" program under supervision of the Yes. monitor and with specific req's re: referral fees and other fee sharing No No Yes. Yes: auditing; policy changes; confidential reporting; press release Yes. Yes: supervised by independent monitor No No Yes Yes, permanent restrictions, monitoring of controls No No Not as a covenant, but a Yes - pursuant to separate agreement with HHS representation by the Company No No Yes. Yes: auditing; new management; policy changes Yes - Continued use or modification of existing internal controls and No procedures to ensure fair and accurate records; compliance code Yes - Adoption or modification of existing internal controls and No procedures to ensure fair and accurate books, records and accounts and a rigorous anti-corruption compliance code, including periodic testing No No No Yes: auditing; data collection No No No No No No Yes, continue implementation of compliance program, review and modify No as needed internal controls, provide reports to DOJ Yes, retained Skadden Arps as Yes, review internal controls Compliance Counsel Yes, submit report to EPA for three years, site inspections, abatement, No training, renovation of heating system No No No No, only cooperation with investigation Yes - conditioned on implementation and auditing of remedial measures No represented as already taken No No, only cooperation with investigation No No No No No Yes No No Yes; reports to compliance officer; effective system of reporting and No controls; training No Not stated Yes (previous SEC agreement); new outside director; confidential Yes. reporting Yes Yes, corporate integrity agreement with HHS Unknown Unknown Yes; compliance program, submit reports to DOJ; new internal controls; No internal reporting mechanisms No Yes, new corporate compliance plan Yes - new procedures to prevent violations of immigration laws, review of No books and records policies and procedures to ensure internal controls exist to prevent illegal billing practices Yes: revise ethical standards, in accord with U.S. Sentencing Guidelines; Yes. hire Executive Ethics Officer; ethics training; written reports No. No (restitution = remedy in lawsuits referenced in agreement) No None stated No Continuing the already implemented measures Yes. Yes, per monitor's recommendations. No Injunctive policy changes; data collection; auditing N/A. Yes; Corporate Integrity Agreement (CIA); code of conduct; new written No policies; training/education; electronic records Yes; continue compliance program; review of existing internal controls; No compliance code; written report No Yes; continue compliance program No Yes, will spend $9.7 million to enhance anti-money laundering program Yes - to be Yes; continue compliance program and other remedial measures in place approved by DOJ Yes Yes, Compliance Office, needs assessment, training, hotline Yes; continuation of compliance program, including: compliance code; No new system of accounting/financial procedures; training; periodic testing No Yes - adherence to previously implemented enhancements No No Yes. Yes. Yes Yes, Compliance Office, needs assessment, training, hotline Yes: new policies (training and educational program); new auditing firm; Yes. appointed independent examiner Yes - approved Yes; continue compliance program, review of internal controls; by DOJ, 2 years compliance code; compliance officer; training; effective system for No Yes Yes; compliance code; continue compliance program; review internal No controls; confidential reporting Yes; must adopt recommendations of special committee of BOD, sa well No. as ethics and compliance program per certain U.S. sentencing guidelines Yes; compliance program; modify existing controls; compliance code; No compliance officer; proper system of financial and accounting No Yes; terminate employment of [redacted]; not do business with [redacted] Yes; corporate compliance program; revise internal controls; compliance No officer; financial and accounting procedure overhaul; training/certification; Yes - internal controls and training with respect to compliance with obligations under Qualified Intermediary Agreement between Company No and IRS; revised governance structure for legal and compliance functions; also, adoption of Exit Program for exit of company from the US cross-border business No Yes, incorporates Consent Order with Comptroller of the Currency No No Yes -- 3 years, Yes; corporate compliance program; internal accounting controls; approved by DOJ compliance code; training/certification; reporting system; Yes: new policies; confidential reporting; training programs; create Yes position of Chief Compliance Officer, new General Counsel. No, but Company must report Yes - strengthening of compliance, bookkeeping and internal controls periodically to standards and procedures; periodic reporting to USDOJ DOJ Yes, outside Yes, new Executive Chairperson on Board, Compliance Committee on Compliance Board, outside Compliance Counsel Counsel Unknown Unspecified remedial actions Yes - for 18 Yes month duration No No Yes; internal accounting controls; compliance code; senior official No. oversight Yes: hiring of Internal Audit Director; reporting hotline; compliance Yes. program; compliance committee; training program; whistleblower protection; compliance reports to USAO E.D.N.Y. Yes No No Yes - approved Yes; compliance program; training; hotline; needs assessment; by DOJ compliance officer; consulting services Yes Yes Yes (John Ashcroft, Yes Ashcroft Group) Pre-Agreement Compliance Unrelated Terms Yes; implementation of compliance program that includes retaining various senior officers and counsel to ensure No adherence to FCPA Yes; implementation of compliance and ethics program No None noted No None cited No None cited No $9.5M restitution; structural/policy changes; internal No investigation Yes; internal investigation with results reported to DOJ; cooperation with DOJ; implementation of compliance and No ethics program Internal investigation; remedial actions taken No Yes; implementation of compliance and ethics program No None Cited No None noted No Yes; implementation of compliance and ethics program No Yes; implementation of compliance and ethics program No Unspecified remedial actions No Unspecified remedial actions No Certain corporate governance reforms, incl. ensuring committee review of internal audit, ensuring disclosure committee establishment, establishing enhanced No governance procedures and implementing a general insurance risk-transfer policy Replacement of officers; issued restated financials; revised Board governance, including establishment of independent No chaiman; revised controls, policies and procedures and instituted training Revised policies with respect to responding to grand jury No subpoenas None cited No None Cited No Yes; implementation of compliance program (specifics No unknown as Exhibit "1" missing) None listed No Immediate disclosure; voluntary cooperation; termination of No employees; compliance program Compliance program implemented, including reporting system, helpline, training, certification process, review No committee None listed No Retained law firm to conduct investigation; shared results No Investments in personnel and compliance systems No None cited No Yes: new management took over No No No None cited No Self-reporting; termination of executives and employees identified as responsible for the misconduct; cessation of No business activities by offending subsidiary Pre-agreement ethics codes No Fulfillment of material obligation in separate plea agreement; enter into separate Civil None cited settlemen Agreement; enter into separate Corporate Integrity Agreement with HHS None cited No Yes, $20 million to be paid to state trust fund Yes, represents that it created an enhanced compliance administered by Foundation for affordable program health services Yes: changes to ethics and compliance program; interim agreement with Air Force in 2005; appointing “Special No Compliance Officer” as a monitor Entering SEC consent decree, retained independent Yes: endow chair in ethics at Seton Hall Law advisor; personnel changes; created two positions on Board School of Directors; reporting None noted No Agreement with OSFI and Federal Reserve of NY (new No policies) None noted No None noted No Self-reporting; further remedial measures to insure against No reoccurrence Self-reporting; further remedial measures to insure against No reoccurrence None noted No None noted No Terminate employees; add two independent directors to board; new CEO; reorganize Finance and Internal Audit No Departments Yes: 3000 hrs community service; teach ethics classes Substantial efforts to make U.S. interests whole; change in No management and new Executive committee Voluntary termination of offending conduct No Yes; implemented program of enhanced training and No compliance with respect to the sale of PSE Yes; implementation of compliance and ethics program No Yes; retained independent compliance officer and instituted No enhanced compliance program Compliance policies, compliance officer and committees, No training, auditing Yes; internal control systems enhanced No None cited No None cited No No No Froze illegal accounts No Remedial action taken to insure integrity of financial reporting, including establishing a full-time dedicated CFO; appointment of financial expert as audic committee chair; No adoption of code of ethics; implementation of new policies & procedures; establishment of training program; revision of D&O indemnification policy Yes, cited initiation of compliance program and cooperation No Yes; implementation of compliance program with "permanent" restrictions / controls re: illegal gambling; No cooperation in criminal investigation Yes; code of compliance, governance committees, No separate chief compliance officer None noted No None noted No None noted No Self-reporting; further remedial measures to insure against No reoccurrence Extensive corrective actions with ongoing supervision of Yes: Fund community serv projects NRC Drafted a Code of Business Ethics No Yes; internal investigation of criminal conduct and reporting of findings; cooperation in external investigation; remedial No measures Yes; internal investigation; sharing of results of Can object to corporate charter for any investigation, including attorney-client privileged reorganized entity emerging from information; removal of involved officers / employees; bankruptcy "on any basis" and in exercise of appointment of new management; cooperation with sole discretion) ongoing investigations. None stated No Appointment of independent director who will serve on Audit Committee; parent company representation at Audit Committee meetings; creation of Complex Transaction If Company fails to dissolve subsidiary Committee to review reinsurance transactions; Cologne Re Dublin within 3 years, DOJ may enhancement of review and reporting by Internal Audit; consider such fact in determining establishment of Risk Committee; institution of training and compliance under the agreement implementation of underwriting rules; preparation to dissolve offending subsidiary None cited No None stated No No No Adoption of new compliance policies; payments in SEC consent decree; new management, new CEO, CFO, new Chief Compliance Officer, new General Counsel; No terminated employees; confidential hotline; retained consultant Self-discovered and reported violations; unspecified No "extensive" remedial efforts None noted No Independent review of hiring practices; self-reporting of No violations Yes, compliance and ethics program implemented No Yes; conducted internal investigation and reported results; cooperation with external investigation; pre-investigation No. compliance measures, such as policy changes, audits, etc. Voluntary disclosure; prompt disciplinary action; no prior No history No No Self-reporting; further remedial measures to insure against No reoccurrence Yes; free public workshop held quarterly to train employers re: how to complete I-9 Yes; cooperation with U.S. and other regulatory agencies. forms, adhere to the best IMAGE practices, etc. Yes, including review of alleged illegality, training, new code of conduct, Chief Compliance Officer appointed, replacing No sales staff Company shall not sell or transfer any of its Change in ownership and control and management interest in JB Oxford Compant to Irving personnel Knott or any of Irving Knott's known associates None noted No Internal investigation; voluntary disclosure; waived privilege; No new policies Yes, remedial measures No None cited No Company shall not re-employ an officer or elect as director any individual who formerly Compliance and ethis program implementation served in such position on or before the date of the agreement New compliance policies; internal investigation voluntary No notification; waived privilege Internal investigation and review of operations, including regular and detailed updates of findings to USDOJ (and D.A No of County of New York) None noted No Yes, previous compliance program to be revised No None cited No None cited No None cited No Administrative payment to U.S.; new compliance policies No Voluntary disclosure; disciplinary action of employees, no No prior criminal history Yes; agency cooperation No. None cited No Internal investigation; voluntary reporting; new policies No None No None noted No Yes, retained forensic accounting firm No None cited No Internal investigation, institution of compliance program; reformation of business practices; discontinuance of No offending referral program Internal investigation; termination of responsible employees; institution of enforcement measures; institution of circulation audits; implementation of field-testing; No enhanced verification procedure; payment of $83 million in restitution Formation of oversight committee; retain outside firm to Yes: Video lottery terminals installed at review; new policies; confidential reporting racetracks Yes; already had compliance program in place No Internal investigation; prompt reporting to DOJ; No implementation of compliance and ethics program Yes, implementation of a compliance policy No New policies and compliance structure; confidential Yes: Gift to Alumni Ass'n for Coast Guard reporting; compliance program; new management Academy to endow chair for envtl study No No No No This NP agreement is one in a series of interconnected agreements between None cited Company and USDOJ, OIG-HHS, OPM and other parties Yes, conducted investigations into compliance, creation and No implementation of compliance program Yes, conducted investigation during due diligence concerning public offering, instituted “extensive remedial No compliance measures” Not unrelated, but must take out ads in None stated newspapers informing public of their misdeeds None cited No None cited No Remedial measures, including Audit Committee investigation, amendment of code of ethics, implementation No of new policies and procedures and development of education program None cited No Yes, side letter agreement premised on full performance of No Pharmacia & Upjohn LLC DPA Yes, notes “remedial actions to date” No None cited No “[E]xceptional remedial measures” and separate agreements with the SEC, the Federal Reserve Bank of No Cleveland and Federal Reserve Board, and the Office of the Comptroller of the Currency None stated No Yes, notes "remedial actions to date" No None listed No None noted No Unknown Unknown Yes, notes "extensive remedial efforts already undertaken" No Yes, adoption of internal controls No Termination/discipline of responsible employees; company- wide training; issuance of I-9 self audit guidelines; No implementation on new payroll software; training investigators; appointing a CCO Yes: previously adopted compliance program and prior Yes: $4M in free health care to the public Corporate Integrity Agreement with HHS None referenced. No. None stated No Yes; termination of responsible employees; hired No Compliance officer; compliance and ethics program; anonymous reporting; trainingby outside legal counsel, Yes; initiation of investigation voluntary disclosure to DOJ and SEC; cooperation with No. ongoing investigation None listed No Yes; compliance program; Compliance officer No Yes; implementation of enhanced compliance program No Yes; revision and enhancement of corporate ethics and No compliance; other remedial measures Yes, describes “considerable resources” devoted to No remedial measures prior to agreement Yes; banned prior CEO from premesis; compliance and auditing program; committed to retention of independent No monitor; whistle-blower hotline; Yes, cites remedial actions to date, including “robust No compliance program” Yes; implementation of compliance program; review of No internal controls Implementation of enhanced compliance procedures No No No Simultaneous compliance agreement with SEC No None cited No Retained firm to conduct internal investigation; shared results; waived privilege; termination of new employees; No new management appointed; restructured Board of Directors, new policies; confidential reporting Yes; enhanced compliance program No Yes, notes “long-standing compliance program” No Yes; voluntarily expanded internal investigation; appointed No compliance officer; compliance policy; revised code of conduct None specifically referenced. No. audit team; revised code of conduct; training program; Yes; voluntary investigation, hired compliance officer; internalNo No No No Yes; investigation; other remedial measures that are unspecified Company agrees to disclosure of certain Cooperative efforts; provision of data client data to the Government Yes, notes “considerable resources” devoted to improved No compliance procedures Yes, subsequent merger and management change with No compliance reforms Yes; cites unspecified remedial actions No Yes: cites “remedial actions to date” without detailing them No Unspecified remedial actions No Yes, new compliance and ethics program implemented No Unspecified remedial actions No Unspecified remedial actions No Yes: cites “remedial actions” taken including “a No comprehensive compliance program” None referenced. No. Yes: terminated employment of those involved; committed to hiring new President, General Counsel, Internal Audit No Director; instituted comprehensive compliance program Yes: “remedial actions to date” cited No Unspecified remedial actions No Yes, retained Ernst & Young LLP and other remedial No measures None noted No Foreign / Domestic Priv. Waiv. Reg. Agency Incorporated Firm No None Foreign No; but withholding on grounds of privilege shall be a factor in None Foreign determining whether full cooperation exists No USAID Domestic No SEC, USPIS Domestic Domestic Yes None Domestic No None Domestic No; but withholding on grounds of privilege shall be a factor in None Domestic determining whether full cooperation exists No SEC (separate agreement) Foreign Yes None stated Foreign No None Foreign No IRS Domestic No None Foreign None stated None stated Domestic None stated None stated Domestic No SEC Domestic Yes SEC; USPIS Domestic No None stated Domestic No None Domestic Yes SEC Domestic Yes No Domestic No None Domestic Yes IRS Domestic Yes SEC Domestic No; but withholding shall be a factor in determining SEC Domestic whether BHI has fully cooperated No Fin-CEN Domestic Yes None Domestic No None Domestic No None Foreign No USPIS, SEC, CFTC Foreign Not stated None Domestic Yes None Domestic No HUD; FHA Domestic No HHS-OIG, USPIS Domestic Yes, limited to the matter under Health & Human Services Domestic investigation Not stated None Domestic Yes None Domestic No NASA, NASA -OIG, USAF, DOD-OIG Domestic Yes None Domestic No; but withholding on grounds of privilege shall be a factor in CFTC Domestic determining whether BP has fully cooperated Yes SEC Foreign Not stated None stated Domestic Office of Foreign Asset Controls No Domestic (OFAC), Treasury Dept.; SEC No None stated Foreign No None stated Foreign No USPIS, SEC Domestic DHS; Immigration & Customs No Domestic Enforcement Yes SEC Domestic Domestic Domestic Domestic No None Foreign No None stated Foreign No DEA Domestic No SEC Foreign No SEC Foreign No HHS-OIG, USPIS Domestic No IRS Foreign Yes, but does not extend to opinions of counsel, mental None stated Domestic impressions of counsel or legal advice Yes SEC, USPIS Domestic OIG-HHS Domestic SEC, Office of Foreign Assets Control of Yes Domestic the Dept. Treasury No None Domestic Yes, but does not apply to protected FBI; USPIS Domestic information created after 1/1/2003 No No Domestic No, but in considering whether to withhold privileged docs, ESI instructed to "tak[e] into account whether providing None Domestic access to the requested material would assist the Monitor in performing its duties . . . . " No OIG-HHS, FBI, USPIS Domestic No FDA Domestic Domestic No None Domestic No USDA Domestic No None stated Foreign NA NRC Domestic No IRS Domestic No; but withholding on grounds of privilege shall be a factor in None Domestic determining whether full cooperation exists No FBI, OIG-HHS, VA Domestic Yes. SEC Domestic FBI Domestic SEC Domestic Yes, limited to matter under investigation, excluding attorney work-product No SEC Domestic N/A IRS Foreign No OIG-HHS, TMA, VA Domestic No None stated Domestic No SEC, IRS, USPIS Domestic No None stated Domestic No None Foreign Domestic N/A No SSA Domestic Domestic No; but withholding on grounds of privilege shall be a factor in SEC; USDOJ, Criminal Division, Fraud Domestic determining Section whether Ingersoll- Rand has fully cooperated No. OIG-HHS Domestic Yes SEC Domestic Not stated No Domestic No None stated Foreign None, but uses standards from U.S. Yes. Dept. of Homeland Security, Immigration Domestic and Customs Enforcement ("IMAGE") No HHS, VA, FDA Domestic No SEC; NASD (now FINRA) Domestic No IRS Domestic Yes None Domestic No OIG-HHS Domestic Yes IRS Domestic No None stated Domestic Already waived None Domestic Domestic No None stated Foreign No SEC Domestic No HHS-OIG Domestic No SEC Domestic Domestic Domestic USPIS, Dep't Treasury Inspector Gen for Yes Domestic Tax Admin No SEC Domestic Already waived None Domestic Yes SEC Domestic No. IRS, USPIS Domestic No CFTC Domestic Domestic Yes None Domestic No None Domestic Domestic None None Foreign No None Domestic No None stated Domestic HHS, Office of Inspector General No Domestic (separate agreement) USPIS; IRS Domestic Yes None Domestic No None Domestic No SEC Foreign Yes SEC Domestic Yes None Domestic Not stated FBI Domestic No None stated Domestic HHS, Office of Inspector General (OIG- HHS); Office of Personnel Management Domestic (OPM) No None stated Foreign SEC; USDOJ, Criminal Division, Fraud No Foreign Section No FBI, EPA Domestic No FBI Domestic No No Domestic No FBI; SEC Domestic No FBI, Department of Labor Domestic No No Domestic No No Domestic No ICE Domestic Yes None Domestic Yes BIS Foreign Yes SEC Domestic Yes (limited) SEC, USPIS Domestic No HHS-OIG Domestic HHS, Office of Inspector General Unknown Domestic (separate Corporate Integrity agreement) No None stated Domestic Yes FERC Domestic No None stated Domestic Domestic Yes None Domestic Domestic No. SEC Domestic Domestic Domestic Yes FDA Domestic No Labor, DOL-OIG, DOT-OIG, MTA-OIG Domestic No. SEC Domestic Yes None Domestic Domestic Yes HHS-OIG, OPM Domestic No None stated Foreign No None stated Domestic No DEA, IRS Domestic No Commerce Domestic No HHS-OIG, USPIS Foreign No None stated Foreign HHS, Office of Inspector General No Domestic (separate Corporate Integrity agreement) Unknown FBI Foreign SEC Foreign No HHS-OIG, USPIS Domestic Domestic Previously waived SEC, USPIS Domestic No FBI Foreign No SEC Domestic No Not stated Domestic No. (p. 2 does not appear to be waiver, since only IRS Domestic applies to docs voluntarily provided by THUSA) Domestic No None stated Foreign Yes, limited to OIG-HHS, OPM Domestic matters under No SEC Domestic No IRS Foreign Federal Reserve Board, Dept. Treasure, No Domestic Office of Comptroller of the Currency No No Foreign No None stated Domestic Yes None Domestic Domestic No None stated Domestic Yes None Domestic No None stated Domestic Florida AG is also a party to the No Domestic agreement USPIS, Dep't Labor, OIG, IRS, Dep't Yes Domestic State Diplomatic Sec Serv No. None. Domestic No USPIS Domestic SEC Domestic Yes CFTC Domestic No USPIS, FBI, OIG-HHS Domestic No; but withholding on grounds of privilege shall be a factor in SEC Domestic determining whether York Int'l has fully cooperated No HHS, USPIS Domestic Publicly Listed Firm (in Fine Foreign Firm Fine U.S.) Yes $30,420,000 $30,420,000 Yes $7,000,000 $7,000,000 No (parent, ABT Inc. is $2,121,688 listed) Yes $0 No N/A Yes $30,000,000 Yes $0 Yes $2,000,000 Yes $1,600,000 $1,600,000 No 0 0 Yes 0 0 No 0 Yes $92,000,000 $92,000,000 Yes $0 No (American Express and many others are listed, $0 however) Yes $80,000 Yes $100,000 Yes $7,500,000 Yes 0 Yes $60,000,000 Yes 0 No 0 No 0 Yes 0 Yes $0 Yes $20,000,000 Yes $0 Yes $10,000,000 Yes $0 $0 No $0 $0 Yes $0 No (BDO Capital is listed) $0 Yes $0 Yes $0 No (Biovail Corp. is listed, $22,200,000 but Biovail Pharm is not) No $0 No (NJ, SC, TX, Wisconsin listed, as is $20,000,000 Wellpoint Health) Yes $50,000,000 Yes $0 Yes $100,000,000 Yes 0 0 No $267,000 Yes $5,000,000 No (Fiat, parent, is listed) See Fiat See Fiat No (Fiat, parent, is listed) See Fiat See Fiat Yes $0 No $1,500,000 Yes $0 No (ConAgra Food, parent, N/A is listed) No N/A No N/A Yes $0 $0 Yes $0 $0 No (CVS Caremark Corp and other CVS $0 subsidiaries are listed) Yes $93,600,000 $93,600,000 No (DaimlerCrysler, $0 $0 parent, is listed) Yes $0 Yes $0 $0 No $0 Yes $75,000,000 Yes $97,050,266 $97,050,266 Yes $0 Yes $0 Yes $0 No $2,500,000 No $9,114,342 Yes $0 Yes $10,500,000 No N/A Yes $1,100,000 Yes $0 Yes $7,000,000 $7,000,000 No (FirstEnergy is listed) $23,000,000 No $500,000 Yes $4,000,000 Yes $150,000,000 Yes $0 No N/A Yes $0 Yes $0 No $6,449,802 $6,449,802 Yes $140,000,000 Yes $0 Yes $0 Yes $1,000,000 No (Hitachi Capital is $0 None listed) No N/A Yes N/A Yes $2,565,317 No (IMC Carlsbad, N/A Colonsay are listed) Yes $2,500,000 Yes $36,944,000 Yes (GE Invision) $800,000 Yes $52,000,000 No (Fiat, parent, is listed) See Fiat See Fiat No 214,500 Yes $5,000,000 Yes $2,000,000 No $0 No (John Hancock listed) Yes $3,360,000 Yes $228,000,000 Yes $30,000,000 Yes $0 No N/A Yes $0 $0 Yes $1,000,000 $1,000,000 Yes $30,500,000 Yes No N/A Yes (Medicis Pharma) N/A Yes $0 Yes $0 Yes Yes $450,000 No $75,000,000 No (Mirant Corp. is listed) $11,000,000 No N/A Yes $1,000,000 No (MRA Asset $2,100,000 Management is listed) No N/A Yes $0 $0 No $0 No $0 Yes $1,200,000 No $0 No $3,000,000 Yes $2,590,000 Yes $9,000,000 $9,000,000 No $0 No $0 Yes $0 No $6,143,407 No $823,962 No $70,560,000 $70,560,000 No $1,000,000 $1,000,000 Yes $0 Yes $0 No (Pasha's Group listed) $0 Yes $0 No $0 Yes Yes $19,680,000 Yes $4,500,000 Yes $25,000,000 Yes $2,000,000 $2,000,000 Yes (both Prudential Equity $325,000,000 Fund and Equity Group Yes No $500,000 Yes $40,000,000 Yes $1,700,000 Yes $36,000,000 Yes $3,000,000 No N/A No $0 No N/A Yes $1,100,000,000 Yes N/A No (GSK is listed) See Glaxo Smith Kline Yes $0 No $0 Yes $7,500,000 Yes $62,600,000 Yes Yes $136,936,000 No (Shell Co. listed) $30,000,000 $30,000,000 Yes $2,500,000 No $0 No $12,600,000 Yes $0 $0 No $240,000,000 $240,000,000 Yes $0 Yes $0 $0 Yes $10,500,000 $10,500,000 Yes $0 Yes $0 Yes $0 Yes $240,000,000 $240,000,000 Yes $1,150,000 No $7,350,000 Yes $0 No N/A Yes $13,440,000 $13,440,000 No $65,000 Yes $4,000,000 Yes $0 $0 Yes $21,600,000 Yes $0 $0 Yes $4,400,000 No Yes N/A Yes $1,500,000 Yes $0 Yes $50,000,000 Yes $0 No (Schlumberger Ltd. $18,000,000 Listed) Yes 300,000 Yes $250,000 Yes $32,300,000 No $50,000,000 Yes $0 Yes $10,000,000 Yes $0 Restitution / Disgorgement / Additional Civil Penalty Forfeiture $194,578 $583,734 $715,000,000 $3,700,000 $1,000,000 $40,000,000 $150,000,000 $225,000 20,000 $10,500,000 $21,600,000 $38,000,000 $149,000,000 $337,500,000 $12,112,416 $16,000,000 $15,000,000 $182,404.75 $50,000,000 $100,000,000 $225,000,000 $2,600,000 $75,000,000 $553,663,153 $3,600,000 $5,482,363 $2,300,000 $14,000,000 $10,000,000 $28,000,000 $20,000,000 $19,182,418 $490,612 $32,319 $20,000,000 $33,000,000 $110,000,000 Community Service $25,000,000 to UPSIP Consumer Fraud Fund $2,000,000 $2M to Coast Guard Academy; $1M to Greater New Haven Water Pollution Control Authority $270,000,000 Fines $30,420,000 $7M fine. $2.9 million in fines and restitution $715M restitution $30M fine. $3.7M restitution; civil assessment $1M $2M fine. $1.6M fine None No, based on criminal fine to be paid to Dutch Public Prosecutor $894,674 in forfeiture $92,000,000 fine None $55M settlement of civil and criminal forfeiture claims $80M in fines (assesed assessed against AIG Financial Products Corp.); Disgorgement of $39.8M in fees and $6.5M in prejudgment interest $25M paid to USPIS Consumer Fraud Fund; $100K fine + $800,000,000 disgorged profits paid pursuant to consent and undertakings in SEC Action (incorporated by reference) $7.5M $40M forfeiture to gov't $150M to compensation/settlement fund; $60M fine $255,000 civil forfeiture, $2.5 million civil settlement with R.J. Reynolds Tobacco $20K. $10.3M reimbursement fund; $200,000 costs None listed None $21.6M settlement; $20M fine $12M restitution; $26M in civil settlements $10M settlement with gov't $149,000,000 forefeiture, and an additional $149,000,000 to Manhattan District Attorney $337.5M to U.S. bankruptcy estate in Refco case and victims; further payments depending on sale price of bank $12,112,416 in restitution $16M restitution Up to $50M in restitution ($10M payable immediately); At least $5M compensation to FHA None; simultaneous settlement with DOJ Civil Division $22.2M criminal fines; $2.4M to settle civil claims $182404.75 restitution $20 million $50M penalty, $565M civil settlement $150 million in restitution and compensation; also a $300M compensation fund in separate civil suit $100 million fine; $53,503,000 victim restitution fund; $25 million to US Postal Service Consumer Fraud Fund $80M to SEC $267,000 settlement $20 million in restitution to Iraq Oil Fund; $5 million to New York Country District Attorney's Office; $2 million to OFAC $7 million $7 million None (in light of bankruptcy) $1.5M $225M restitution; $163M civil compensation in separate civil suit $2.75M settlement with gov't; $725,000 to Ariz. None (Up to $3M for material breaches of the NPA ($150K per breach); up to $7.5M fine stipulated if prosecution is instituted ($500K per felony offense)) $286M forfeiture (additional $286M forfeiture to D.A. of County of New York under separate agreement) $2,600,000 restitution, $75,000,000 civil penalty $93,600,000 None 553663153 forfeiture None $75M and $200,000 in costs to U.S. Postal Service $97,050,266 for Elan Corp. for criminal penalty; $3.6M forfeiture for US subsidiary EPI. $5.482,363 in disgorgement $2.3 million disgorgement None $2.5 million $9,114,342.00, plus any additional funds identified that are related to illegal internet gambling operations Separate $2,991,889 settlement of administrative and civil claims $10.5 million $1.1 million Full restitution $7 million $23M fines; $4.3M community service $668,141 restitution for unpaid lax liability; $500K fine $4M Separate criminal fines pursuant to conviction, and civil settlement of $88,000,000 to federal government and $60,000,000 to s $2M to the United States Postal Inspection Service Consumer Fraud Fund (plus any difference between $2M and >$2M total amount paid to other governmental agencies as part of bankruptcy) $47,555 to six private individuals $60.5 million restitution to AIG shareholders in settlement of civil class action; $19.5 million to USPIS Consumer Fraud Fund $29.6M in fines, restitution; $16,195,999 disgorgement, $6,989,324 restitution $600,000,000 in separate civil action None ($100M in SEC settlement; $445M class settlement); $3M to U.S. Postal Service $1 million None $18,132,000 forfeiture; $2,565,317.51 in fines for FSLA violations $2.5 million $36,944,043.00 plus interest to U.S. and Medicaid Participating States $800,000 fine $100 million total penalty, and additional $10 million may be assessed, or more, and determination of fine may be appealed to “a retired federal judge selected by the United States sitting as an independent Special Master.” $7 million $214,500.00 $17,262,078 ($12,262,078 in forfeited profits and $5 million in fines) $2 million None $900,000 civil assessment; $110,000 to Mass. State Ethics Commission $3,360,000 $456M total, of which $228M consists of fines $30 million fine; $806,431 restitution $4.28M restitution; $4.43M administrative payment; $300,000 reimbursement; $3M civil penalty $175 million forfeiture (additional $175 million forfeiture to D.A. of County of New York under separate agreement) $1 million $30.5 million $750M restitution (SEC agreement) $30,000 in costs, $18.1M in restitution to taxpayers, U.S. $80M (SEC agreement) $3.8M restitution; $4.91M administrative payment; $3M civil penalty; $300,000 reimbursement $450,000 fine $75M, plus interest $11 million fine $1M fine $2.1M fine None $136 million civil forfeiture, distribution of $94 million to U.S. customers $850,000 restitution $1.2 million $15 million (jointly and severally) in settlement of civil forfeiture action $3M fine $2.59M fine $9 million $500,000 civil forfeiture $19,182,418.18 forfeiture $6,143,407 fine $832,962.90 plus interest $70,560,000 $1 million $490,612 restitution $105 million forfeiture None None Pursuant to DPA and guilty plea of Pharmacia, supra $15 million in addition to criminal fine pursuant to guilty plea of $19,680,000 $4.5 million $90M restitution fund; $25M fine Fine and restitution paid pursuant to guilty plea of subsidiary $270,000,000 in SEC settlement to Fair Fund; additional $5,000,000 penalty to Commonwealth of Massachusetts $330M settlement with SEC Pursuant to guilty plea: $500,000 fine; $3,087,277.60 to federal and state Medicaid, $20 million to Virginia Prescription Monitoring Program trust account; $5,300,000 to Virginia Medicaid Fraud Control Unit’s Program Income Fund; $276,100.000 forfeiture; $160 million civil settlement; $40 million + $262 million civil settlement to resolve False Claims Act allegation + $6.2 million to Medicare to resolve other civil claims $1,700,000 $36 million $1 million to US; $2 million to City of Houston None $1.1B $159,502,000 combined federal settlement $20,000,000 restitution $7.5M to be paid by its subsidiary SSI Korea $62. 6M fine $136,936,000 paid pursuant to parallel plea agreement $30,000,000 foreign fine $2,500,000 $15 million forfeiture, $12 of which to satisfy civil fine by Financial Crimes Enforcement Network $12,600,000 None $240,000,000 None $33 million forfeiture $10.5M (separate $10.5M disgorgement to SEC) None $139M to compensation fund; $3M to U.S. Postal Service $240,000,000 $1.15 million $7,350,000 None -- requires filing of amended tax returns. $13,440,000 $65,000 $4,000,000 $380 million disgorgement of profits; $400 million federal backup withholding tax, interest penalties and restitution $21.6 million $5,334,331 forfeiture $4,400,000 Full restitution in amount determined by Monitor, $4.9M to Medicaid $1.5 million None $50M fine, $110,000,000 forfeiture $80 million plus interest ($40 million restitution + $40 million civil forfeiture) $18M fine, $1.6M in costs $300,000.00 $350,000 fine, $13.3M restitution $32.3 million in fines and disgorgement and $7.25 interest $50M fine. $10 million None Can DOJ Unilaterally Terminate Length Agreement? 3 years Yes 3 years Yes 27 months Yes 2 years. Yes. 15 months. Yes. None listed Yes. 3 years + one week Yes 3 years Yes 3 years No 2 years Yes 2 years Yes 3 years + one week Yes 3 years No 1 year Yes 2 years (1 year if compliant) Yes. 3 years Yes 2 years Yes 1 year Yes. 2 years. Yes. 3 years Yes Until full fine payment made (if payment scheduled followed, full payment would be No effectuated, at latest, one year + 10 days from date of execution of ag'mt) Gov't conclude investigation in 90 days Yes. None listed Yes. 2 years Yes 12 months. Yes. 3 years (can be terminated earlier) Yes. 1 year Yes. 2 years Yes None N/A. 3 years Yes No, DOJ must initiate proceedings in the 18 months. district court to determine whether a breach occurred 5 years Yes 18 months Yes 3.5 months No 2 years Yes 2 years Yes No: but “conduct by a Boeing employee classified at a level below Executive Management . . . shall not be deemed to 2 years. constitute conduct by Boeing” and “USAO's shall provide Boeing with written notice” of belief a breach occurred. Special Master will adjudicate any breach. 2 years. Yes. 3 years Yes 3 years. Yes. 1 year (or ends whenever all 4 payments Yes are made) 2 years Yes 3 years Yes 3 years Yes 2 years Yes 2 years Yes 18 months. Yes. 2 years Yes 2 years Yes Yes, but Company may appeal within 3 years higher branch of DOJ 2 years + 1 week Yes 2 years + 1 week Yes 18 months Yes 2 years Yes 5 years Yes 2 years. No 2 years Yes 1 year Yes 4 months Yes 2 year Yes 18 months. Yes 12 months Yes 3 years Yes 2 years Yes Seemingly (no "sole discretion" language, 6 months however) 3 years Yes 12 months. Yes. 2 years, 9 months Yes 3 years. Yes f $88,000,000 to federal government and $60,000,000 to states 3 years from date of execution of agreement, or final approval of bankruptcy Yes. reorganization plan, whichever is later 2 years 1 year Yes 3 years Yes 18 months. None specified Unclear Seemingly (no "sole discretion" language, 2 years however) 30 months. Yes. Seemingly (no "sole discretion" language, 2 years however) Unclear Yes None specified (various time limits apply for implementation of compliance and remedial Yes measures) 3 years Yes 2 years. No. 2 years. Yes. 3 years Yes 3 years Yes Yes, upon written notice, and with 14 day 24 months. cure period. Not stated Yes No, Federal District Court for the Central 3 years District of California must find that breach occurred Not stated Yes None listed Yes. 6 months Yes 14 months (can be extended at one year intervals; max. 5 yrs); monitorship lasts Yes. three years 3 years Yes None listed Yes. 2 years Yes 2 years Yes 2 years Yes 2 years. Yes. 3 years. 21 months. Yes. None listed No 3 years. Yes (for 24 months) later of: 24 months, or date upon which all Yes, subject to 14 day cure and 30 day payment obligations satisfied "appeal" within DOJ 15 months Yes 3 years. Yes. Yes (provides for notice and two week 3 years. opportunity to demonstrate no breach or cure) Unclear Yes 2 years Yes None explicitly stated - restitution payment Yes schedule spans 3 years, 9 months 3 years (5 year term on separate agreement Yes with HHS) 15 months Yes 18 months. Yes. Not explicitly stated - must deliver progress Not stated reports for three years 3 years Yes Until criminal investigations and prosecutors Yes are final 2 years. Yes. 3 years or until all criminal trials are final Not stated (whichever is later) Yes 2 years Yes 3 years + 1 week Yes 18 months Yes 3 years Yes None specified - restitution payment No schedule extends for 3.5 years Not specified Not stated Not specified Yes Seemingly, but does not use "sole 2 years discretion" language 3 years Yes 3 years Yes 5 years No Yes, upon written notice with two week 1 year opportunity to demonstrate no breach 2 years Not stated 60 months Yes 3 years. Yes. 6 years Yes Unknown Unknown 3 years Unknown 2 years Yes Seemingly (no "sole discretion" language, 18 months however) 2 years; may be extended up to a total of 5 Yes. years if there are violations later of: 2 years, or date upon which all prosecutions based on identified conduct No. final Until payment is made Unknown 3 years Yes 3 years. Yes. 18 months. Yes. 5 years No 3 years + 7 days Yes 2 years (but can extend for up to two more Yes years if investigation is not finished) 1 year Yes, within 6 months of material breach 36 months Yes 18 months Yes 2 years Yes, if breach 24 months. Yes Not stated Unknown 3 years. Yes. 18 months Yes 3 years. Yes. 2 years + 1 week Yes, if breach Not stated Yes 3 years + 1 week Yes 3 years. No. 3 years + 1 week Yes 2 years Yes, if breach 2 years Yes 18 months, 30 days Yes 1 year Yes 2 years Yes 3 years + 1 week Yes 2 years (can be extended 1 year) Yes. Seemingly (no "sole discretion" language, 3 years however) 3 years Yes 12 months Yes, if breach 3 years (with allowance for a reduction to 2 Yes years) 1 year Yes. Seemingly (no "sole discretion" language, 3 years. however) 3 years. Yes. 3 years 15 months. Yes. 12 months Yes, if breach 3 years Yes 18 months Yes
"Excel spreadsheet - University of Virginia.xls"