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Wiley Rein LLP

Sittenfeld v. United States – Campaign Contributions as Crimes?

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The Supreme Court may soon accept a pivotal case – Sittenfeld v. United States – that could redefine when a political contribution becomes a crime. In this two-minute video, Caleb Burns discusses how the outcome of this case...more

Wiley Rein LLP

Sittenfeld v. United States – Campaign Contributions as Crimes?

Wiley Rein LLP on

The Supreme Court may soon accept a pivotal case – Sittenfeld v. United States – that could redefine when a political contribution becomes a crime. In this two-minute video, Caleb Burns discusses how the outcome of this case...more

Wiley Rein LLP

[Podcast] "Dumplings,” Diamonds, & Plea Deals: Brazil’s Operation Car Wash

Wiley Rein LLP on

Power and corruption … two sides of a wicked coin. In this podcast, hosts Tatiana Sainati and Diana Shaw tell the stories of the world’s largest, most salacious corruption scandals and explore the myriad ways in which...more

Thomas Fox - Compliance Evangelist

The Foreign Corrupt Practices Handbook: Interview with the Authors

I recently spoke with the Foreign Corrupt Practices Act (FCPA) Handbook authors Robert Tarun and Peter Tomczak from Baker McKenzie for a two-part podcast episode. The depth of knowledge and experience in white-collar crime,...more

Guidepost Solutions LLC

Emerging Expectations from the Latest Enforcement Actions Over Off-Channel Communications

Since December 2021, the U.S. Securities and Exchange Commission (SEC) and Commodity Futures Trading Commission (CFTC) have levied almost $3.0 billion in penalties for longstanding failures by 39 broker-dealers, swap dealers,...more

Nossaman LLP

Compliance Notes - Vol. 4, Issue 42

Nossaman LLP on

Welcome to Compliance Notes from Nossaman’s Government Relations & Regulation Group – a periodic digest of the headlines, statutory and regulatory changes and court cases involving campaign finance, lobbying compliance,...more

The Volkov Law Group

Deutsche Bank FCPA and Fraud “Spoofing” Settlement: A Review of Deutsche Bank Conduct (Part II of II)

The Volkov Law Group on

Deutsche Bank’s ethics and compliance function faces numerous challenges.  Deutsche Bank has a storied record of scandals, government enforcement actions and failures to abide by prior deferred prosecution agreements (DPAs)....more

The Volkov Law Group

2020 Year in Review: Interesting Enforcement Actions (Part III of IV)

The Volkov Law Group on

DOJ and the SEC each had a great year in FCPA enforcement.  But it is important to acknowledge that the blockbuster case, Goldman Sachs, was the driver of this successful year. ...more

Society of Corporate Compliance and Ethics...

[Event] April Basic Compliance & Ethics Academy - April 27th - 30th, Chicago, IL

Our Basic Academies are ideal for professionals with some compliance knowledge and experience who are ready to support, enhance and manage a comprehensive compliance program. They are taught by compliance professionals,...more

The Volkov Law Group

2019 FCPA Enforcement Highlights (Part II of III)

The Volkov Law Group on

In a record year, there are bound to be numerous interesting enforcement actions and principles.  I picked out a few to highlight....more

Thomas Fox - Compliance Evangelist

Fresenius FCPA Enforcement Action

The long-awaited Fresenius Medical Care AG & Co. KGaA (FMC) Foreign Corrupt Practices Act (FCPA) enforcement action was recently announced. It involved massive multi-year and multi bribery schemes by the company in multiple...more

The Volkov Law Group

Textbook Lessons Learned from the Société Générale and Legg Mason FCPA Enforcement Action (Part III of III)

The Volkov Law Group on

Sometimes it takes a large enforcement action to underscore basic and important anti-corruption compliance principles. The Société Générale enforcement action demonstrated two important principles – the dangers of a weak...more

Thomas Fox - Compliance Evangelist

This Week in FCPA-Episode 80, The Last Jedi Edition

Jay and I return for a wide-ranging discussion on some of the top compliance- and ethics-related stories of the week, including: 1. There are several FCPA 40th anniversary pieces going up these days. The FCPA Blog is looking...more

The Volkov Law Group

Pushing Ethics and Compliance Programs in the New FCPA Corporate Enforcement Policy

The Volkov Law Group on

The Justice Department’s aggressive enforcement program, particularly in the FCPA arena, has been the primary impetus to the growth and empowerment of the corporate compliance function. The Justice Department and SEC’s FCPA...more

Thomas Fox - Compliance Evangelist

Compliance Under the New FCPA Enforcement Policy – Final Thoughts

Over the past few posts I have been exploring the Department of Justice’s (DOJ) new policy regarding Foreign Corrupt Practices Act (FCPA) enforcement. Deputy Attorney General Rod Rosenstein, in a speech, called it the FCPA...more

Thomas Fox - Compliance Evangelist

New FCPA Enforcement Policy Ends the Compliance Defense Debate

As I continue my exploration of the new Department of Justice (DOJ) policy regarding Foreign Corrupt Practices Act (FCPA) enforcement, the FCPA Corporate Enforcement Policy (Policy), one of the things that struck me was the...more

Thomas Fox - Compliance Evangelist

A New Owner and New CEO: Will Anything Change?

Tilman Fertitta has purchased the Houston Rockets from current owner Les Alexander for the stunning sum of $2.2 bn. The sales price breaks the National Basketball Association (NBA) record sale of $2 billion from when the...more

Thomas Fox - Compliance Evangelist

LRN Compliance Program Effectiveness Report: Part I (and Farewell to Chuck Berry)

Last week I interviewed Susan Divers, Senior Advisor at LRN Corporation, on the company’s 2016 Ethics and Compliance Program Effectiveness Report (Report). The Report was a fascinating review of the evolution of compliance...more

The Volkov Law Group

The Real Explanation for the Record Year for FCPA Enforcement

The Volkov Law Group on

All the FCPA prognosticators, predictors and paparazzi have missed the boat on understanding what happened this year – 2016, to make this a record year in FCPA enforcement. As a former public servant for over 20 years, I am...more

The Volkov Law Group

The SEC’s Continuing Refinement of Internal Controls Enforcement

The Volkov Law Group on

My good friend and colleague, Tom Fox, has written an interesting post on the SEC’s recent United Airlines settlement for $2.4 million for domestic bribery. As Tom has noted, the interesting aspect of the SEC’s enforcement...more

The Volkov Law Group

The SEC’s Year of FCPA Enforcement

The Volkov Law Group on

Say what you will – the SEC is making its mark this year in FCPA enforcement. So far, the SEC has brought nine separate enforcement actions, the latest with Bristol-Myers Squibb. I am sure we will see more before the end of...more

The Volkov Law Group

The Danger of Compliance Overkill

The Volkov Law Group on

Government prosecutors spend time promoting enforcement programs and encouraging companies to design and implement effective ethics and compliance programs. The blogosphere is filled with articles, surveys, studies, warnings,...more

Thomas Fox - Compliance Evangelist

FCPA Compliance and Ethics Report-Episode 122-with Matt Kelly on Alstom, Avon and Petrobras

In this episode, Compliance Week Editor-in-Chief Matt Kelly and I discuss the Avon and Alstom FCPA enforcement actions and then take a look at the ongoing Petrobras corruption scandal and what it means for Brazil. ...more

NAVEX

2015 Trends: #5 Regulatory Enforcement Moves Down Market

NAVEX on

While ethics and compliance scandals that implicate brand name companies tend to grab the headlines, smaller organizations have always borne the brunt of regulatory enforcement. Over the years, U.S. Sentencing Commission data...more

Thomas Fox - Compliance Evangelist

FCPA Compliance and Ethics Report-Episode 121-FCPA Year in Review, Part II

In this episode I review the two Opinion Releases, Esquenazi court decision, DOJ communications via speeches on FCPA enforcement. I end with a look at 2015. ...more

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