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?
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
The Development: After an interruption during the COVID-19 pandemic, authorities across the Asia-Pacific region have fully revived dawn raids....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
Signed into law on December 22, 2023, the Foreign Extortion Prevention Act (FEPA) signals a further focus by the U.S. government on anti-corruption enforcement. Our White Collar, Government & Internal Investigations Team...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
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 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
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
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
As we move towards one year that most everyone is ready to exit, I wanted to consider some of the key enforcement actions from both the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) in 2020. You...more
Contrary to some expectations, the Trump Administration Department of Justice imposed record penalties under the U.S. Foreign Corrupt Practices Act from 2017 through 2020. But in each of those years, fewer and fewer new FCPA...more
The SFO has concluded a deferred prosecution agreement with Airline Services Limited (ASL), a UK supplier of aircraft cabin parts and services, for failure to prevent bribery under s7 Bribery Act 2010. Despite the company...more
Beam Suntory, a global producer and distributor of distilled beverages, settled its FCPA case with DOJ for $19.5 million for bribes paid in India. The DOJ settlement follows an SEC FCPA settlement for $8 million announced...more
We rarely have seen a single Foreign Corrupt Practices Act (FCPA) enforcement action generate so many individual criminal pleas. The Sargeant Marine Inc. (Sargeant Marine) case is an exception. To date, there have been six...more