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Excel spreadsheet - University of Virginia.xls

VIEWS: 12 PAGES: 130

									               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

								
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