ANTICORRUPTION DEVELOPMENTS -
MTS Receives DOJ and SEC Declination Letters Concluding FCPA Investigations -
On August 7, 2017, MTS Systems (MTS), a Minnesota based maker of test systems and industrial position...more
9/2/2017
/ Africa ,
Anti-Corruption ,
Appeals ,
China ,
Civil Liability ,
Compelled Testimony ,
Department of Justice (DOJ) ,
Due Diligence ,
Enforcement Actions ,
Executive Orders ,
Exports ,
Financial Conduct Authority (FCA) ,
Foreign Corrupt Practices Act (FCPA) ,
Freight Forwarding ,
Guilty Pleas ,
Hong Kong ,
IPSA ,
Iran Sanctions ,
Libor ,
New Legislation ,
North Korea ,
Office of Foreign Assets Control (OFAC) ,
Payment Processors ,
Russia ,
Sanction Violations ,
SDN List ,
Securities and Exchange Commission (SEC) ,
Singapore ,
South Africa ,
Trump Administration ,
Venezuela ,
Whistleblowers
• A divided 2nd Circuit holds that there is no requirement for a “meaningfully close personal relationship” between a tipper and tippee in order for the tipper to reap a personal benefit from the disclosure sufficient to give...more
ANTICORRUPTION DEVELOPMENTS -
U.K. Opens Corruption Investigation of Rio Tinto over Guinea Operations -
On July 24, 2017, the United Kingdom’s Serious Fraud Office (SFO) announced that it had opened an investigation into...more
8/10/2017
/ Anti-Corruption ,
Bribery ,
Corruption ,
Criminal Prosecution ,
Cuba ,
Customs and Border Protection ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Executive Orders ,
Export Controls ,
Fédération Internationale de Football Association (FIFA) ,
FinCEN ,
Foreign Corrupt Practices Act (FCPA) ,
Forfeiture ,
Guilty Pleas ,
Hackers ,
Hobby Lobby ,
Iran Sanctions ,
Money Laundering ,
Office of Foreign Assets Control (OFAC) ,
Sanction Violations ,
Securities and Exchange Commission (SEC) ,
Serious Fraud Office (SFO) ,
Sudan ,
Suspensions & Debarments ,
World Bank
ANTICORRUPTION DEVELOPMENTS -
U.K. Opens Corruption Investigation of Rio Tinto over Guinea Operations -
On July 24, 2017, the United Kingdom’s Serious Fraud Office (SFO) announced that it had opened an investigation into...more
8/10/2017
/ Anti-Corruption ,
Bribery ,
Corruption ,
Criminal Prosecution ,
Cuba ,
Customs and Border Protection ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Executive Orders ,
Export Controls ,
Fédération Internationale de Football Association (FIFA) ,
FinCEN ,
Foreign Corrupt Practices Act (FCPA) ,
Forfeiture ,
Guilty Pleas ,
Hackers ,
Hobby Lobby ,
Iran Sanctions ,
Money Laundering ,
Office of Foreign Assets Control (OFAC) ,
Sanction Violations ,
Securities and Exchange Commission (SEC) ,
Serious Fraud Office (SFO) ,
Sudan ,
Suspensions & Debarments ,
World Bank
ANTICORRUPTION DEVELOPMENTS -
U.K. Opens Corruption Investigation of Rio Tinto over Guinea Operations -
On July 24, 2017, the United Kingdom’s Serious Fraud Office (SFO) announced that it had opened an investigation into...more
8/3/2017
/ Anti-Corruption ,
Bribery ,
Corruption ,
Criminal Prosecution ,
Cuba ,
Customs and Border Protection ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Executive Orders ,
Export Controls ,
Fédération Internationale de Football Association (FIFA) ,
FinCEN ,
Foreign Corrupt Practices Act (FCPA) ,
Forfeiture ,
Guilty Pleas ,
Hackers ,
Hobby Lobby ,
Iran Sanctions ,
Money Laundering ,
Office of Foreign Assets Control (OFAC) ,
Sanction Violations ,
Securities and Exchange Commission (SEC) ,
Serious Fraud Office (SFO) ,
Sudan ,
Suspensions & Debarments ,
World Bank
ANTICORRUPTION DEVELOPMENTS -
Linde Group Receives DOJ Declination Pursuant to FCPA Pilot Program -
On June 16, 2017, German based chemical and gas company Linde Group’s American affiliates, Linde North America Inc....more
7/4/2017
/ AIG ,
Anti-Corruption ,
Bribery ,
Civil Monetary Penalty ,
Compliance ,
Corruption ,
Criminal Penalties ,
Cuba ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Disgorgement ,
Economic Sanctions ,
Enforcement Actions ,
Export Controls ,
Exports ,
Fédération Internationale de Football Association (FIFA) ,
Fines ,
Foreign Corrupt Practices Act (FCPA) ,
Guilty Pleas ,
Iran Sanctions ,
Kokesh v SEC ,
Office of Foreign Assets Control (OFAC) ,
SCOTUS ,
Securities and Exchange Commission (SEC) ,
Statute of Limitations ,
Theft ,
Trade Secrets ,
Trump Administration ,
White Collar Crimes
ANTICORRUPTION DEVELOPMENTS -
Steven Peikin Reported to Become Co-Director of SEC’s Enforcement Division -
On May 26, 2017, The Wall Street Journal reported that recently confirmed Commissioner Jay Clayton will hire...more
6/12/2017
/ Anti-Corruption ,
Bribery ,
Criminal Prosecution ,
Czech Republic ,
Defense Contracts ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Espionage ,
Export Controls ,
Financial Conduct Authority (FCA) ,
General-Business ,
Guilty Pleas ,
International Trade ,
Money Laundering ,
NAFTA ,
Office of Foreign Assets Control (OFAC) ,
Presidential Appointments ,
Public Comment ,
Sanction Violations ,
Securities ,
Securities and Exchange Commission (SEC) ,
Serious Fraud Office (SFO) ,
Singapore ,
Suspensions & Debarments ,
Trump Administration ,
UK ,
Whistleblowers ,
White Collar Crimes ,
World Bank
ANTICORRUPTION DEVELOPMENTS -
Steven Peikin Reported to Become Co-Director of SEC’s Enforcement Division -
On May 26, 2017, The Wall Street Journal reported that recently confirmed Commissioner Jay Clayton will hire...more
6/12/2017
/ Anti-Corruption ,
Bribery ,
Criminal Prosecution ,
Czech Republic ,
Defense Contracts ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Espionage ,
Export Controls ,
Financial Conduct Authority (FCA) ,
General-Business ,
Guilty Pleas ,
International Trade ,
Money Laundering ,
NAFTA ,
Office of Foreign Assets Control (OFAC) ,
Presidential Appointments ,
Public Comment ,
Sanction Violations ,
Securities ,
Securities and Exchange Commission (SEC) ,
Serious Fraud Office (SFO) ,
Singapore ,
Suspensions & Debarments ,
Trump Administration ,
UK ,
Whistleblowers ,
White Collar Crimes ,
World Bank
ANTICORRUPTION DEVELOPMENTS -
Steven Peikin Reported to Become Co-Director of SEC’s Enforcement Division -
On May 26, 2017, The Wall Street Journal reported that recently confirmed Commissioner Jay Clayton will...more
6/1/2017
/ Anti-Corruption ,
Bribery ,
Criminal Prosecution ,
Czech Republic ,
Defense Contracts ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Espionage ,
Export Controls ,
Financial Conduct Authority (FCA) ,
Guilty Pleas ,
Money Laundering ,
NAFTA ,
Office of Foreign Assets Control (OFAC) ,
Presidential Appointments ,
Public Comment ,
Sanction Violations ,
Securities and Exchange Commission (SEC) ,
Serious Fraud Office (SFO) ,
Singapore ,
Suspensions & Debarments ,
Trump Administration ,
UK ,
Whistleblowers ,
White Collar Crimes ,
World Bank
ANTICORRUPTION DEVELOPMENTS –
Former Magyar Telekom Executives Settle Bribery Charges –
On April 24, 2017, the Securities and Exchange Commission (SEC) announced that two former executives of Magyar Telekom, a...more
5/10/2017
/ Anti-Bribery ,
Anti-Corruption ,
Bribery ,
Compliance ,
Cooperation ,
Corruption ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Export Controls ,
Exports ,
Foreign Corrupt Practices Act (FCPA) ,
Internal Investigations ,
Russia ,
White Collar Crimes
Anticorruption Developments -
Former Magyar Telekom Executives Reconcile Bribery Charges -
April 24, 2017, the US Securities and Exchange Commission (SEC) announced that the Hungarian telecommunications company...more
5/10/2017
/ Anti-Bribery ,
Anti-Corruption ,
Bribery ,
China ,
Compliance ,
Corruption ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Export Controls ,
Foreign Corrupt Practices Act (FCPA) ,
Securities and Exchange Commission (SEC) ,
White Collar Crimes
ANTICORRUPTION DEVELOPMENTS –
Former Magyar Telekom Executives Settle Bribery Charges –
On April 24, 2017, the Securities and Exchange Commission (SEC) announced that two former executives of Magyar Telekom, a...more
5/2/2017
/ Administrative Resignation ,
Bribery ,
Criminal Convictions ,
Customs and Border Protection ,
Department of Justice (DOJ) ,
Disgorgement ,
Enforcement Actions ,
Executive Orders ,
Export Administration Regulations (EAR) ,
Exports ,
Foreign Corrupt Practices Act (FCPA) ,
Guilty Pleas ,
Illegal Activity ,
Jones Act ,
Kokesh v SEC ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Penalties ,
Red Notices ,
Sanction Violations ,
SCOTUS ,
SDN List ,
Securities and Exchange Commission (SEC) ,
Settlement ,
Statute of Limitations ,
Steel Industry ,
Suspensions & Debarments ,
Trade Deficit ,
Trade Expansion Act of 1962 ,
Trump Administration
Anticorruption Developments -
SEC Chairman Nominee Jay Clayton Receives Confirmation Hearing -
On March 23, 2017, SEC Chairman Nominee Jay Clayton testified before the Senate Banking Committee at his confirmation...more
4/4/2017
/ Anti-Retaliation Provisions ,
Arrest ,
Bribery ,
CFIUS ,
China ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Export Controls ,
Exports ,
Federal Pilot Programs ,
FinCEN ,
Foreign Corrupt Practices Act (FCPA) ,
Investors ,
Iran Sanctions ,
Office of Foreign Assets Control (OFAC) ,
Petrobras ,
Sanction Violations ,
Securities and Exchange Commission (SEC) ,
Senate Confirmation Hearings ,
Sentencing ,
Split of Authority ,
Telecommunications ,
Trump Administration ,
Ukraine ,
Whistleblowers
Acting SEC Chief Limits Subpoena Authority to Enforcement Division Acting Director -
On February 15, 2017,The Wall Street Journal reported that the acting Chair of the Securities and Exchange Commission (SEC), Michael...more
3/2/2017
/ Anti-Corruption ,
Civil Monetary Penalty ,
Compliance ,
Conflict Mineral Rules ,
Economic Sanctions ,
Enforcement Actions ,
Export Controls ,
Exports ,
Foreign Corrupt Practices Act (FCPA) ,
Iran Sanctions ,
Office of Foreign Assets Control (OFAC) ,
Rescission ,
Resource Extraction ,
Russia ,
Securities and Exchange Commission (SEC) ,
Trump Administration ,
Whistleblowers
ANTICORRUPTION DEVELOPMENTS -
Las Vegas Sands Corporation Agrees to Pay Approximately $7 Million to Resolve DOJ FCPA Enforcement Action –
On January 19, 2017, Las Vegas Sands Corporation (“Sands”), a Nevada-based...more
ANTICORRUPTION DEVELOPMENTS -
Las Vegas Sands Corporation Agrees to Pay Approximately $7 Million to Resolve DOJ FCPA Enforcement Action –
On January 19, 2017, Las Vegas Sands Corporation (“Sands”), a Nevada-based...more
2/1/2017
/ CFIUS ,
Cuba ,
Disgorgement ,
Economic Sanctions ,
Export Controls ,
Foreign Corrupt Practices Act (FCPA) ,
General Licenses ,
Iran Sanctions ,
Office of Foreign Assets Control (OFAC) ,
Rolls-Royce ,
SCOTUS ,
Suspensions & Debarments ,
World Bank
Anticorruption Developments -
The U.S. Court of Appeals for the 10th Circuit Rules That the SEC's Use of ALJs is Unconstitutional
- On December 27, 2016, the U.S. Court of Appeals for the 10th Circuit ruled 2-1...more
1/3/2017
/ Administrative Law Judge (ALJ) ,
Cyber Attacks ,
Enforcement Actions ,
Export Controls ,
Foreign Corrupt Practices Act (FCPA) ,
Office of Foreign Assets Control (OFAC) ,
Red Notices ,
Russia ,
Sanctions ,
SDN List ,
Suspensions & Debarments ,
Teva Pharmaceuticals
On December 6, 2016, in an opinion written by Justice Alito, the Supreme Court unanimously affirmed the Ninth Circuit’s decision in Salman v. United States, a closely-watched insider trading tipping case. Salman builds upon...more
JPMorgan Resolves Enforcement Action Regarding China Subsidiary’s Hiring Practices -
On November 17, 2016, JPMorgan Chase & Co. (JPMC) entered into a nonprosecution agreement with the Department of Justice (DOJ), and...more
On October 2, 2016, the National Security Division (NSD) of the U.S. Department of Justice (DOJ) established a formal, voluntary self-disclosure program for criminal violations of U.S. economic sanctions and export controls...more
On November 16, 2015, the U.S. Department of Justice revised the United States Attorneys’ Manual (USAM) to align the principles by which federal government prosecutors investigate and prosecute criminal cases involving...more
On September 9, 2015, the U.S. Department of Justice issued guidance regarding the prosecution of individuals in cases involving criminal and civil corporate wrongdoing. The first major policy memorandum issued since Attorney...more
On January 29, 2015, the Department of Defense (DOD), the National Aeronautics and Space Administration (NASA) and the General Services Administration (GSA) published the final anti-human trafficking rule amending the current...more
2/2/2015
/ Amended Legislation ,
DFARS ,
Federal Acquisition Regulations (FAR) ,
Federal Contractors ,
Final Rules ,
General Services Administration (GSA) ,
Human Trafficking ,
Manufacturers ,
NASA ,
Regulatory Standards ,
Subcontractors ,
Supply Chain
In a landmark insider trading decision issued on December 10, 2014, the U.S. Court of Appeals for the 2nd Circuit made important pronouncements favorable to the defense on two recurring and important legal issues: (1) what is...more
From November 18 to 19, 2014, the American Conference Institute held its annual U.S. Foreign Corrupt Practices Act (FCPA) conference outside of Washington, D.C. Keynote speakers including U.S. Department of Justice (DOJ)...more
11/25/2014
/ Chief Compliance Officers ,
Compliance ,
Department of Justice (DOJ) ,
Foreign Corrupt Practices Act (FCPA) ,
Internal Controls ,
Investigations ,
OECD ,
Professional Conferences ,
Securities and Exchange Commission (SEC) ,
Self-Reporting ,
Strategic Enforcement Plan