An experienced whistleblower attorney, successful trial attorney, former criminal prosecutor, and former reporter Representing whistleblowers reporting fraud on the Federal State Governments

The Securities and Exchange Commission is expanding the pool of public companies being examined about their compliance with U.S. sanctions against IRan and many other nations on our blacklist of individuals and entities grows. It is increasing its comment letters to companies and requesting more information related to dealings in countries targeted by U.S. sanctions. According to the Wall Street Journal over 42 companies received letters from the SEC regarding activity in areas subject to sanctions enforced by the Treasury Department’s Office of Foreign Assets Control.

T SEC has sent letters to companies such as  PayPalHoldings Inc., Bank of New York Mellon Corp. and Chinese travel-services provider Ctrip.comLtd. with sanctions-related questions. 1,500 individuals or entities were added to the U.S. sanctions list



The United States has imposed new sanctions on Irans complex and extensive shipping that it uses to sell oil, and the U.S. will pay $15 million to anyone with information that disrupts the scheme. The reward could be rendered to individuals living within or outside the United States.

The Treasury Department placed sanctions on 26 individuals and “entities” affiliated with the Islamic Revolutionary Guards Corps Quds Force. The sanctions freeze any assets within the United States concerning those individuals or corporations affiliated with the shipping network. It also prevents them from doing business with Americans. It also identified 11 ships, placing anyone who owns or operates them on a Treasury list and exposing any port that lets them in, or firms that fuel or offload them, to future sanctions.

 Rostam Ghasemi, Iran’s former minister of petroleum oversees and operates the network.

 International SOS Assistance, Inc., International SOS Government Services, Inc., International SOS, LP, Air Rescue Americas, Inc. Arnaud Vaissié; and Pascal Rey-Herme (collectively, “International SOS”), will pay $940,000 settling allegations that it overcharged TRICARE, the health care insurance system for members of the military services and their families. The overcharges related to aeromedical evacuation services by concealing discounts it received from third-party air ambulance providers in violation of the False Claims Act.

International SOS, is a provider of overseas healthcare services for the government and it had negotiated discounts from third-party air ambulance providers, which it was required to pass along to TRICARE. Instead, International SOS did not disclose the actual cost of the aeromedical evacuation services during the quoting process; billed TRICARE at the higher non-discounted amount; and received payment from TRICARE for the inflated costs, which International SOS contends it retained as a fee.

This settlement resolves allegations in a lawsuit by a former International SOS Regional Flight Desk Manager, under the qui tam (or whistleblower) provisions of the False Claims Act. The qui tam provisions permit private parties to sue for false claims on behalf of the government and to receive a share of any recovery. The relator here will receive $165,000 as his share of the recovery in the case. The relator was represented by Franklin J. Rooks, Jr., Esq. of Morgan Rooks, P.C., and Jared A. Jacobson, Esq. of Jared Jacobson Law, LLC.

The Clearing Corporation will pay $20 million to the US as penalties, following a Securities and Exchange Commission investigation finding the company failed to implement policies to manage certain risks as required by U.S. laws and SEC and CFTC rules.  According to the SEC’s and CFTC’s  orders, Chicago-based OCC failed to establish and enforce policies and procedures involving financial risk management, operational requirements, and information-systems security.  The SEC’s order also found that OCC changed policies on core risk management issues without obtaining required SEC approval.

As the U.S.’s sole registered clearing agency for exchange-listed option contracts on equities, OCC was designated in 2012 as a systemically important financial market utility, or SIFMU.  That designation makes OCC subject to enhanced regulation and transparency regarding its risk management systems because disruption to OCC’s operations might be costly not only for itself and its members, but other market participants or the broader financial system.  Today’s enforcement action is the SEC’s first charging violations of SEC clearing agency standards adopted in 2012 and in 2016, and the CFTC’s first charging violations of Core Principles applicable to Derivatives Clearing Organizations.

“As a clearing agency, OCC performs a range of services that are critical to the effective operation of the securities markets,” said SEC Chairman Jay Clayton.  “Today’s resolution is intended to ensure that OCC will have appropriate policies and procedures in place to meet its obligations to our financial system.”

New York’s Department of Consumer Protection has sued T-Mobile allegedly sold used phones as new devices, charging illegal taxes and charging fees for unwanted services.

The lawsuit says there were more than 2,000 violations of the city’s consumer protection law which were revealed in consumer complaints and a year-long investigation by the city’s Department of Consumer and Worker Protection. It found deceptive practices in stores across the five boroughs.

Resit Tavan, a Turkish Businessman and owner of the Istanbul-based Turkish business Ramor Dis Ticaret Ltd. (also known as the “Ramor Group”) was sentenced on Thursday, Aug. 29, 2019, in Federal District Court in Milwaukee, Wisconsin, to 27 months imprisonment in connection with his conviction for conspiracy to violate U.S. sanctions by exporting specialized marine equipment from the United States to Iran between 2013 to 2015. Tavan, a Turkish citizen, had pleaded guilty to a conspiracy to violate U.S. sanctions on Iran under the International Emergency Economic Powers Act by using his Turkish based company, the Ramor Group, to acquire a range of marine related equipment that had been manufactured in Wisconsin by U.S. companies, including high powered outboard engines, marine power generators and power boat propulsion equipment known as surface drives, on behalf of the Iran-based Qeshm Madkandalou Shipbuilding Cooperative (Madkanadalou).  Evidence introduced in Court showed that Tavan had worked in cooperation with Iranian officers associated with Madkandalou to use some of this U.S. origin marine equipment to support the construction and development of a prototype high-speed missile attack boat for the Iranian military or naval forces.  From early 2013 through 2015, Tavan and the Ramor Group had worked in concert with Iranian officials to procure U.S. origin marine equipment and illegally export it to Iran by using the Ramor Group in Turkey to receive the goods and thereafter re-export it to Madkandalou in Iran, in violation of U.S. sanctions.

At the sentencing hearing, the District Court Judge indicated that this conspiracy to violate U.S. sanctions by procuring marine equipment for military purposes represented a serious threat to U.S. national security.  The Judge also found that Tavan’s role in the offense should be considered in connection with the overall direction and control of the project by higher ranking Iranian officials.

At no time did anyone involved in these transactions obtain permission from the U.S. Department of Treasury, Office of Foreign Assets Control or the U.S. Department of Commerce to export any U.S.-origin marine equipment from the United States to Iran.

GateHouse Media data analysts say Chinese importers are misclassifying of products to the US by changing product codes to avoid the higher tariffs. In particular, the analysis reveals nearly a dozen Chinese imports — including woven fabrics, furniture mounts and lamps are being misclassified. The findings correspond with the information provided during interviews with at least 20 traders, brokers, economics researchers and former and current government officials that offer a rare peek into how easy it is for some companies to avoid Trump’s new duties.

To date, the United States has imposed additional tariffs on some $250 billion in Chinese products. China has responded with tariffs of its own, affecting some $110 billion of U.S. goods .

Every type of product shipped to the United States bears its own 10-digit classification code, known as the Harmonized Tariff Schedule code, or HTS. Dried black pepper is 0904.11.00.20, for example; dried white pepper is 0904.11.00.30.

The Securities and Exchange Commission today announced the institution of settled cease-and-desist proceedings against Juniper Networks, Inc., a California-based networking and cybersecurity solutions company, for violations of the Foreign Corrupt Practices Act (FCPA) through its subsidiaries in Russia and China. Juniper agreed to settle charges that it violated the internal accounting controls and recordkeeping provisions of the FCPA and to pay more than $11.7 million in monetary relief.

According to the SEC’s order, certain sales employees of Juniper’s Russia subsidiary secretly agreed with third-party distributors to fund leisure trips for customers, including government officials through the use of off-book accounts. Even after a member of Juniper’s senior management learned of the misconduct in Russia, the order states, Juniper’s remedial efforts were ineffective, and the misconduct continued for over three years. Additionally, the order finds that, certain sales employees of Juniper’s Chinese subsidiaries falsified trip and meeting agendas for customer events to understate the true amount of entertainment involved in the trips.

Juniper Networks Inc. is an American multinational corporation headquartered in California.  It develops and markets networking products, including network security, routers, switches and other products.

The Securities and Exchange Commission awarded more than $1.8 million to a whistleblower who provided critically important information assisting  an enforcement action involving overseas misconduct. TheSEC’s redacted award order (pdf) didn’t provide other details about the whistleblower or the company involved. By law, the SEC protects the confidentiality of whistleblowers and doesn’t disclose information that could reveal their identity.

The SEC said the whistleblower provided “extensive and ongoing cooperation” that included the “review of documents and the provision of sworn testimony.”“The misconduct occurred abroad, and without the whistleblower’s tip and assistance, the violations at issue would have been difficult to identify,” chief of the SEC’s Office of the Whistleblower Jane Norberg said.

The SEC said the agency has made awards to at least four “overseas” whistleblowers.

The Securities and Exchange Commission today announced an award of more than $1.8 million to a whistleblower whose information and assistance was critically important to the success of an enforcement action involving misconduct committed overseas.

After alerting the agency to the violations, the whistleblower provided extensive and ongoing cooperation during the course of the investigation, including the review of documents and the provision of sworn testimony, and continued to provide additional new information that advanced the investigation.

“The whistleblower in this matter provided stellar information and ongoing assistance that resulted in the Commission bringing a programmatically significant enforcement action,” said Jane Norberg, Chief of the SEC’s Office of the Whistleblower. “Moreover, the misconduct occurred abroad, and without the whistleblower’s tip and assistance, the violations at issue would have been difficult to identify.”