Episode 383 -- FCPA Update: Declination and Indictment
10 For 10: Top Compliance Stories For the Week Ending August 23, 2025
Daily Compliance News: August 21, 2025, The Fabricated Evidence Edition
Daily Compliance News: August 19, 2025, The AI Winter Edition
Daily Compliance News: August 18, 2025, The All Corruption Edition
10 For 10: Top Compliance Stories For the Week Ending August 16, 2025
Daily Compliance News: August 15, 2025, The Privilege Protected Edition
Daily Compliance News: August 14, 2025 The End of Dial Up Edition
Daily Compliance News: August 13, 2025. The Bad App Store Ratings Edition
Daily Compliance News: August 12, 2025, The ABC Angle Edition
FCPA Compliance Report - Episode 770 - Integrating ESG in Global Outsourcing: Insights from Inge Zwick
Compliance Tip of the Day – Final Thoughts on Pre - Acquisition Due Diligence in M&A
La Consulta Popular
Compliance Tip of the Day: Key M&A Enforcement Actions
FCPA Compliance Report: Navigating Corporate Scandals: Insights on Governance, Compliance, and Recovery with Steve Vincze
10 For 10: Top Compliance Stories For the Week Ending, August 2, 2025
Everything Compliance: Episode 158, The No to Corruption in Ukraine Edition
Everything Compliance: Shout Outs and Rants: Episode 157, No To Ukraine Corruption
Daily Compliance News: July 28, 2025, The Where is Grasshopper when you need him Edition
Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption law and enforcement developments from the past...more
We recently had a Foreign Corrupt Practices Act (FCPA) enforcement action that reminded me that everything old is new again in anti-corruption compliance. The Securities and Exchange Commission (SEC) FCPA enforcement action...more
In March 2024, the Department of Justice (DOJ) announced the resolution of a Foreign Corrupt Practices Act (FCPA) enforcement action involving the Swiss trading firm G Trafigura Beheer B.V. (Trafigura), an international...more
We continue our exploration of the resolution of the FCPA enforcement action involving the Swiss trading firm Gunvor S.A. The enforcement action came in with a $661 million penalty against the company, which has pleaded...more
While 2023 was a relatively slow year in FCPA enforcement, the DOJ and SEC settlements announced throughout the year set out a list of important ethics and compliance reminders. While these may seem obvious to everyone, I...more
2023 was a very significant year for every compliance practitioner and compliance program. While there was a paucity of corporate enforcement actions under the Foreign Corrupt Practices Act (FCPA), there were significant...more
UN Corruption Convention’s Ratification - In October 2003, the General Assembly officially ratified the United Nations Convention against Corruption (“Corruption Convention”). Since that time, a total of 190 countries have...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
Survey: Tech gaps, third parties pose biggest ABAC threats - Compliance professionals surveyed regarding their anti-bribery and corruption efforts (ABAC) indicated resource support deficiencies in areas including staffing...more
Here are some basic propositions that surround FCPA compliance. It is often underplayed that the FCPA contains more than just a bribery prohibition – the FCPA contains broad provisions, requiring accurate books and records...more
In the FCPA and white collar defense community, we have seen buckets and buckets of ink spilled on the coming wave of aggressive enforcement. Justice Department officials have made so many statements about the “new” approach...more
Even with the absence of any major DOJ FCPA enforcement actions, DOJ issued an interesting FCPA Opinion Letter last week addressing application of the FCPA in circumstances where organizations face imminent serious bodily...more
You could begin with the Transparency International-Corruption Perception Index (TI-CPI) to garner a sense of the reputation of the country in which your business unit is located, as well as the CPI for all other countries in...more
On July 3, the Criminal Division of the U.S. Department of Justice (“DOJ”), and the Enforcement Division of the U.S. Securities and Exchange Commission (“SEC”) released an updated joint Resource Guide to the U.S. Foreign...more
On July 3, 2020, the Department of Justice (“DOJ”) and Securities and Exchange Commission (“SEC”) updated their 2012 joint guidance on the Foreign Corrupt Practices Act (“FCPA”) in the SEC and DOJ’s FCPA Resource Guide...more
Last week, the Department of Justice (DOJ), without fanfare, released an update to its 2019 Evaluation of Corporate Compliance Programs, the 2019 Guidance. For simplicity this new document will be called the 2020 Update. ...more
One of the lessons we have learned from various Foreign Corrupt Practices Act (FCPA) enforcement actions over the years is how complexity in business organizations can work to defeat compliance programs. ...more
The Department of Justice recently announced updates to its Foreign Corrupt Practices Act Corporate Enforcement Policy. While the changes were relatively minor, the modifications underscored important principles surrounding...more
The original version of the FCPA, enacted in 1977, contained an exception for payments made to non-U.S. officials who performed duties that were “essentially ministerial or clerical”. In 1988 Congress responded by amending...more
I am in a multipart series on the Framework for OFAC Compliance Commitments (Framework). Every compliance professional of any stripe needs to read, understand and implement some of the key concepts of the Framework into your...more
The drumbeat of those supporting ISO 37001 continues. However, I still find it to be misplaced as anything close to the international standard for anti-bribery/anti-corruption programs....more
This episode 30 is Part 2 of my interview with the FCPA Professor. ...more