Episode 383 -- FCPA Update: Declination and Indictment
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 14, 2025 The End of Dial Up Edition
Daily Compliance News: August 12, 2025, The ABC Angle Edition
10 For 10: Top Compliance Stories For the Week Ending, August 2, 2025
Daily Compliance News: July 31, 2025. The Forgotten Generation Edition
Daily Compliance News: July 28, 2025, The Where is Grasshopper when you need him Edition
2 Gurus Talk Compliance: Episode 55 – The From Worse to Worser Edition
Sittenfeld v. United States – Campaign Contributions as Crimes?
Daily Compliance News: July 14, 2025, The Secret Business Sauce-Reading Edition
10 For 10: Top Compliance Stories For the Week Ending, July 12, 2025
FCPA Compliance Report: Stay the Course: Ellen Lafferty on Navigating Anti-Corruption Compliance in 2025
10 For 10: Top Compliance Stories For the Week Ending June 28, 2025
Episode 374 -- Justice Department Resumes FCPA Enforcement with New, Focused Guidance
Compliance Tip of the Day: New FCPA Enforcement Memo - What Does it Say?
As global supply chains continue to realign in response to shifting geopolitical dynamics, tariffs and trade policies, compliance and risk professionals are facing unprecedented challenges. The evolving trade landscape is...more
Companies that self-disclose, cooperate, and remediate could benefit from significantly reduced fines and possible declinations even in cases with aggravating factors. In a speech at Georgetown University Law Center on...more
On January 17, 2023, Assistant Attorney General for the United States Department of Justice Kenneth A. Polite Jr. announced significant revisions to the Criminal Division’s Corporate Enforcement Policy (“CEP”). Four months...more
2021 was a very significant year for every compliance practitioner and compliance program. While there was a paucity of corporate FCPA enforcement actions, the three enforcement actions were significant with multiple lessons...more
We are the end of my multi-part exploration of the Herbalife Nutrition Ltd (Herbalife) Foreign Corrupt Practices Act (FCPA) enforcement action with both the Department of Justice (DOJ) and Securities and Exchange Commission...more
For the first time in six years, the Department of Justice (DOJ) has released an Opinion Release, denominated 20-01. At first blush it appears to be a straight-forward recitation of the equivalent of black letter law in the...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
Most experts agree that whichever regulatory jurisdiction an organisation is subject to, there are five common fundamentals involved in providing effective corporate compliance....more
Yesterday, I considered five Department of Justice (DOJ) Foreign Corrupt Practices Act (FCPA) enforcement actions. Today, I want to look at key FCPA enforcement actions by the Securities and Exchange Commission (SEC)....more
The January 2019 FCPA Digest is an invaluable compendium of all FCPA-related developments in 2018, including US foreign bribery proceedings and criminal prosecutions, DOJ foreign bribery civil actions, SEC actions, DOJ...more
Anti-Corruption enforcement remained a top priority in France, the UK, and the US in 2018. Join our firm's Global Anti-Corruption Team as they explain and analyze these three countries' anti-corruption enforcement efforts and...more
This blog post concludes my multi-part exploration of the Petróleo Brasileiro S.A. – Petrobras (Petrobras) Foreign Corrupt Practices Act (FCPA) enforcement action. Today we consider the stunning result achieved by Petrobras –...more
Yesterday the Securities and Exchange Commission (SEC) resolved a Foreign Corrupt Practices Act (FCPA) enforcement action involving Kinross Gold Corporation (Kinross). ...more
The compliance community is well aware of the risks in the C-Suite. As you move up the corporate ladder, the level of risk from executive misconduct increases. A rotten executive can quickly bring down a company, destroy...more
Why is the focus on the CCO role now concerned with authority and independence? The role of the Chief Compliance Officer (CCO) has steadily grown in stature and prestige over the years....more
A company that commits bribery has to undergo a soul-searching examination of its operations, from top to bottom. Bribery violations come in all shapes and forms – systemic violations like Siemens, Daimler and other...more
In Part IV of my series on ISO 37001, I examine requirements relating to risk assessments, design of policies and procedures, and due diligence requirements. Section 4.5 sets out requirements for conducting risk...more
In Part III of my continuing series on ISO 37001, today I examine the board and top management’s respective responsibilities in the implementation and oversight of an anti-bribery management system....more
In Part II of my continuing series, I identify in broad strokes some of the more significant positive and negative aspects of ISO 37001. While it is easy to second-guess the ISO 37001 authors, there are some interesting...more
To my mind the most significant and important book that every Chief Compliance Officer (CCO), General Counsel (GC) and compliance practitioner needs to read is The Chickenshit Club by Pulitzer Prize winning journalist Jesse...more
Adam West died this weekend. He was the TV Batman I knew growing up. They say the actor who first introduced you to a character will always be your favorite and while I am not sure if that holds true or not with West’s...more
This week I have engaged in a series on how a Chief Compliance Officer (CCO) or compliance practitioner might think about operationalizing a compliance program with other corporate functions and disciplines. I have been...more
A Chief Compliance Officer has a number of important relationships to attend to in the corporate governance landscape. A critical relationship needed to “operationalize” a compliance program is a partnership between a CCO and...more
The Department of Justice (DOJ) and Securities and Exchange Commission (SEC) continued their stunning 2016 run of Foreign Corrupt Practices Act (FCPA) decisions with the announcement of the resolution of the Embraer SA...more
A most “daring act” seems to be a good way to introduce a multi-part look at the recent Foreign Corrupt Practices Act (FCPA) enforcement action involving the Chilean chemicals and mining company Sociedad Química y Minera de...more