On March 20, 2025, the UK's Serious Fraud Office ("SFO"), France's National Financial Prosecutor's Office ("PNF"), and the Office of the Attorney General of Switzerland ("OAG") announced the creation of a new task force to...more
3/31/2025
/ Anti-Corruption ,
Bribery ,
Corporate Counsel ,
Corruption ,
Enforcement Actions ,
Enforcement Guidance ,
Foreign Corrupt Practices Act (FCPA) ,
France ,
Government Agencies ,
International Trade ,
Joint Task Force ,
Serious Fraud Office (SFO) ,
Switzerland ,
UK
As part of the Action Plan for Democracy, the Government of Spain recently established two new specialized prosecutorial units and a new independent whistleblower protection agency....more
The Situation: In September 2024, the U.S. Department of Justice ("DOJ" or "Department") announced updates to its Evaluation of Corporate Compliance Programs guidance covering three primary areas: (1) the risks of artificial...more
10/11/2024
/ Artificial Intelligence ,
Compliance ,
Compliance Management Systems ,
Criminal Investigations ,
Department of Justice (DOJ) ,
Emerging Technologies ,
Employees ,
Machine Learning ,
New Guidance ,
Risk Assessment ,
Risk Management ,
Safe Harbors ,
Whistleblower Protection Policies
In light of the DOJ’s most recent guidance on the use of personal devices and third-party messaging applications by corporate personnel, this White Paper addresses issues and challenges that companies are facing in this area...more
10/18/2023
/ CFTC ,
Compliance ,
Cybersecurity ,
Data Collection ,
Data Privacy ,
Data Protection ,
Department of Justice (DOJ) ,
Electronic Communications ,
Financial Industry Regulatory Authority (FINRA) ,
Guidance Update ,
Instant Messaging Apps ,
Mobile Devices ,
Policies and Procedures ,
Securities and Exchange Commission (SEC) ,
White Collar Crimes ,
Workplace Communication
Across every industry and every region of the world, corporate compliance programs have increasingly become an integral part of a company's operations and procedures—and the trend shows no signs of slowing. In the first in a...more
On July 18, 2023, the French Anticorruption Agency ("FAA") published its 2022 annual activity report. The report detailed key figures related to the inspections carried out by the agency, as well as the lessons to be learned....more
While there are a number of ways in which organizations may become aware of potential wrongdoing internally, perhaps the most significant for its legal and compliance teams is internal reporting, or “whistleblowing,” by...more
5/15/2023
/ Cross-Border ,
Cross-Border Transactions ,
Employment Rights Act ,
EU ,
Financial Conduct Authority (FCA) ,
Foreign Nationals ,
Securities and Exchange Commission (SEC) ,
UK ,
United Arab Emirates (UAE) ,
Whistleblower Protection Policies ,
Whistleblowers
In Short -
The Situation: The European Union's Fourth Anti-Money Laundering ("AML") Directive (Directive (EU) 2015/849 of May 20, 2015) granted broad access to information relating to the beneficial owners of companies...more
On March 14, 2023, the French Anticorruption Agency ("AFA") and the Parquet National Financier ("PNF") jointly published a new version of their guide relating to internal anticorruption investigations (the "Guide")....more
Although French companies have made progress in anticorruption compliance over the past two years, the French Anticorruption Agency ("FAA") has found that they still have difficulty implementing certain measures, particularly...more