Episode 356 -- Trump Administration Hits Pause on FCPA Enforcement
The Line Between Gift Giving and Bribery
The New Cold War: Risk, Sanctions, Compliance Episode 21: "Interview with Drago Kos of the OECD Working Group on Bribery"
Dr. Jan Spafke and Jad Mhanna on Compliance in Non-Western Cultures
Corruption, Crime & Compliance - Episode 208 - A Deep Dive into the WPP FCPA SEC Settlement
Anti-Corruption Compliance and Enforcement Trends in the US and Globally
Doing Business in the European Union | Global Laws & Compliance Program
Gary Kalman on Corruption and Compliance Programs
Integrity Matters: Assessing the Corporate Compliance Climate in 2021-Anti-Bribery and Anti-Corruption Enforcement in 2021
Compliance Perspectives: Risk and the 2020 Compliance & Ethics Institute
Applying Behavioral Science to Compliance – A Conversation with Richard Bistrong, Front-Line Anti-Bribery LLC
Episode 119 -- The Ericsson FCPA Settlement
FCPA Compliance Report-Episode 346, Mike Skopets on Miller’s Summer 2017 FCPA Report
FCPA Compliance Training That's About the 'What Happens' at the Front-lines
FCPA Compliance Report-Episode 329, James Koukios
FCPA Compliance Report-Episode 302-Carlos Ayers on the Odebrecht Settlement from Brazil
How Can We Develop Anti-Bribery Ambassadors?
Joe Spinelli on the Kroll-Ethisphere Anti-Bribery & Corruption Report
Anti-Bribery and Compliance Challenges Ahead
What is the Current State of Anti-Bribery Compliance & Enforcement in Australia?
We have previously written about the impact of the pause in enforcement of the FCPA implemented by the Trump Administration on non-American companies.1 Although the 180-day review period the Executive Order provided to the...more
Anti-bribery and corruption agencies in the UK, France and Switzerland today announced a shared commitment to tackling international bribery and corruption, by way of a new taskforce intended to strengthen collaboration....more
On February 5, 2025, US Attorney General (AG), Pam Bondi, issued a memorandum entitled Total Elimination of Cartels and Transnational Criminal Organizations, in which she provides new guidance to the Department of Justice...more
Newly Appointed US Attorney General Pam Bondi issued a directive shifting the focus of Foreign Corrupt Practices Act investigations and cases away from those that do not involve criminal operations of cartels and...more
On May 10, 2024, Romy Andrianarisoa, former Chief of Staff to the President of Madagascar, was convicted for soliciting bribes from Gemfields Group Ltd (Gemfields), a UK-based mining company specializing in rubies and...more
In the first major action of 2024, the Department of Justice (DOJ) announced it had entered into a three-year deferred prosecution agreement (DPA) with a publicly traded global software company for alleged violations of the...more
This week we are taking a deep dive into the SAP Foreign Corrupt Practices Act (FCPA) enforcement action. In it, SAP agreed to pay the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) approximately...more
When it comes to FCPA enforcement and expectations, DOJ has moved the goalposts. Some would argue that DOJ has been consistent all along. The truth, like most issues, lies somewhere between the extremes....more
The Justice Department’s FCPA enforcement record for 2024 was slow. This trend was unexpected, contrary to my own predictions and of various other prognosticators. It is hard to explain why this slowdown occurred....more
While the Department of Justice (DOJ) has initiated at least two new Foreign Corrupt Practices Act (FCPA) enforcement actions against U.S. companies, it has also announced several decisions not to prosecute—most recently...more
Ericsson, a multinational telecommunications company, based in Sweden, settled its breach of its 2019 Deferred Prosecution Agreement, agreed to enter a guilty plea and pay a $206 million penalty. In 2019, Ericsson entered...more
Foreign Corrupt Practices Act (“FCPA”) enforcement has yet to rebound from the immediate pre-pandemic period. In 2022, DOJ and SEC resolved eight corporate FCPA matters for $878 million, including four resolutions coordinated...more
While Foreign Corrupt Practices Act (FCPA) enforcement activity has not come close to returning to the heights seen a few years ago, 2022 reflected significant increases from the prior year in both the number of cases against...more
The Foreign Corrupt Practices Act (FCPA) (15 U.S.C. § 78dd-1 et seq.) is a federal anti-bribery law that makes it unlawful for certain people to pay foreign government officials in order to conduct business abroad. While it...more
The corruption risks of the telecommunications sector are too often given cursory consideration as, historically, there has been a keener focus on the extractive and energy sectors. Those sectors are considered to have a much...more
On September 15, 2022, GOL Linhas Aéreas Inteligentes S.A. (GOL), Brazil’s second largest domestic airline, resolved long-running parallel investigations by the U.S. Department of Justice (DOJ) and the Securities and Exchange...more
The SEC announced its first FCPA enforcement action in 2022. South Korean telecommunications company, KT Corporation, agreed to pay $6.3 million to settle FCPA violations. As part of the settlement, KT Corp. agreed to pay...more
On January 21, 2022, the Department of Justice (“DOJ”) issued a Foreign Corrupt Practices Act (“FCPA”) Opinion Procedure Release (the “OPR” or “OPR 22-01”) addressing the rarely discussed extortion exception to the FCPA’s...more
A. Basic Overview of Statute - The Foreign Corrupt Practices Act of 1977, as amended, 15 U.S.C. §§ 78dd-1, et seq. (FCPA), makes it unlawful for U.S. persons and entities and others who act within the jurisdiction of the...more
Due to the impact of the COVID-19 pandemic, and the change in presidential administrations in the United States in January 2021, US enforcement of the Foreign Corrupt Practices Act (FCPA) declined in 2021. However, we...more
Recent Deferred Prosecution Agreements (DPAs) show the UK Serious Fraud Office (SFO) scrutinising companies’ compliance programmes. All of the companies which entered into DPAs relating to bribery had anti-bribery and...more
Scores of articles and volumes of commentary have been issued since President Joseph R. Biden, Jr. issued a presidential memorandum (hereinafter, “Memorandum”) making global anticorruption efforts an urgent national security...more
The Justice Department and the Securities Exchange Commission are back in business. The first corporate FCPA enforcement action in 2021 came after a six-month hiatus in 2021. While many commentators sought to read the...more
In remarks at the American Conference Institute’s 37th International Conference on the Foreign Corrupt Practices Act (FCPA) on December 3, 2020, Gen. Brian C. Rabbit, then acting assistant attorney general of the U.S....more
In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international anti-corruption developments from the past month, with links to primary...more