On August 14, 2020, the US Department of Justice (the DOJ) issued its first Foreign Corrupt Practices Act (FCPA) Opinion Procedure Release in six years, which relayed that it did not intend to pursue an enforcement action...more
8/25/2020
/ Advisory Opinions ,
Banks ,
Compliance ,
Corporate Counsel ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Fees ,
Foreign Banks ,
Foreign Corrupt Practices Act (FCPA) ,
Investment Adviser ,
Multinationals ,
State-Owned Enterprises ,
Subsidiaries
On August 9, 2019, the US Court of Appeals for the Second Circuit upheld a Chinese real estate developer’s conviction in United States v. Ng Lap Seng. The Court rejected defendant’s attempt to read an “official act”...more
On May 2, 2019, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued guidance titled “A Framework for OFAC Compliance Commitments” (Guidance), providing direction regarding what OFAC considers to...more
5/15/2019
/ Anti-Money Laundering ,
Audits ,
Chief Compliance Officers ,
Compliance ,
Corporate Governance ,
Corporate Management ,
Department of Justice (DOJ) ,
Dubai ,
Enforcement ,
Enforcement Actions ,
Enforcement Authority ,
Financial Conduct Authority (FCA) ,
Financial Industry Regulatory Authority (FINRA) ,
Foreign Corrupt Practices Act (FCPA) ,
Guidance Update ,
Hong Kong ,
Hong Kong Securities and Futures Commission (HKSFC) ,
Internal Controls ,
Monetary Authority of Singapore ,
Office of Foreign Assets Control (OFAC) ,
Personal Liability ,
Risk Assessment ,
Securities and Exchange Commission (SEC) ,
Singapore ,
Training ,
U.S. Treasury ,
UK
On November 29, 2018, the US Department of Justice (DOJ) modified prior guidance on individual liability for corporate misconduct by affording federal prosecutors discretion to focus on “individuals who play significant roles...more
A former banker has agreed to forfeit $43.7 million and has pled guilty to Foreign Corrupt Practices Act (FCPA) violations and money laundering in one of the largest individual FCPA enforcement cases to date. The two-count...more
On August 24, 2018, the US Court of Appeals for the Second Circuit in United States v. Hoskins rejected the government’s broad reading of the Foreign Corrupt Practices Act (FCPA) and ruled that a foreign national without ties...more
On June 4, 2018, Société Générale S.A., together with a subsidiary of the Paris-based global financial services institution, announced an agreement with both French and American authorities to resolve charges relating to...more
6/13/2018
/ Bribery ,
Criminal Investigations ,
Criminal Prosecution ,
Cross-Border ,
Department of Justice (DOJ) ,
Financial Services Industry ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Governments ,
France ,
Libor ,
Multinationals ,
Popular ,
Price Manipulation
On May 9, 2018, in speech before the New York City Bar White Collar Crime Institute, Deputy Attorney General Rod Rosenstein stated the US Department of Justice (DOJ) will implement a new policy to discourage multiple...more
On November 29, 2017, the US Department of Justice (DOJ) issued a revised Foreign Corrupt Practices Act (FCPA) Corporate Enforcement Policy and sweetened the deal for companies that self-report instances of foreign bribery....more
On Friday, March 10, Kenneth Blanco, the acting assistant attorney general for the Department of Justice’s Criminal Division, announced that the FCPA Pilot Program would not expire on April 5, 2017, as originally scheduled....more
Following recent regulatory announcements and legal decisions, internal investigations are becoming increasingly more complicated to navigate. Join Sutherland for a moderated roundtable where our experienced practitioners...more