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?
Daily Compliance News: May 30, 2025, The Leissner Sentenced Edition
Daily Compliance News: May 28, 2025, The Moron Premium Edition
Daily Compliance News: May 27, 2025, The Boeing Off the Hook Edition
Daily Compliance News: May 22, 2025, The Trump and Dump Edition
Daily Compliance News: May 19, 2025, The Definition of Corruption Edition
10 For 10: Top Compliance Stories For the Week Ending May 10, 2025
Compliance into the Weeds: USRA Declination Case Study - Self-Disclosure Best Practices
Daily Compliance News: April 8, 2025, The End of Monitors Edition
10 For 10: Top Compliance Stories For The Week Ending April 5, 2025
2 Gurus Talk Compliance: Episode 48 – The March Madness Edition
On July 2, 2025, the U.S. Court of Appeals for the Second Circuit ruled in United States v. Lopez that foreign commercial bribery schemes fall within the ambit of the honest services wire fraud statute, 18 U.S.C. §...more
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
In reviewing FCPA bribery fact patterns, it is a rare occasion when a company’s CEO is at the epicenter of the criminal conspiracy. In the BIT Mining case, standing atop all of the actors is the CEO Zhengming Pan, Bit...more
You have to give the Justice Department credit — after two slow enforcement years, DOJ is starting off 2024 with a relative “bang;” first, DOJ reached a large settlement with SAP in January, and now, DOJ has reached a...more
On 21 December 2023, Mr Justice Waksman handed down his judgment in the second trial of the Eurasian Natural Resources Corporation (ENRC) saga. The judgment, along with its earlier companions, is extraordinary in many ways...more
On November 29, 2023, Department of Justice (DOJ or Department) policymakers announced explicitly that they are, for the first time, leveraging data analytics to help proactively identify and prosecute crimes in foreign...more
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 case developments from the past month,...more
On 24 May 2022, Glencore International AG announced a series of coordinated resolutions with various international enforcements agencies including the Department of Justice (”DOJ”), the Commodity Futures Trading Commission...more
The Justice Department announced the arrest and indictment of Charles Hunter Hobson for violating the FCPA, money laundering and receiving kickbacks arising from a bribery scheme to pay government officials in Egypt in...more
While we wait for the coming FCPA enforcement storm, DOJ and the SEC have quietly continued to rack up and resolve several enforcement actions....more
Fraud Scheme Results in $56 Million Seized as Largest Recovery of Cryptocurrency by US - On November 12, 2021, the U.S. Department of Justice and U.S. Attorney’s Office for the Southern District of California’s request was...more
Credit Suisse Group AG (“Credit Suisse”), a global financial institution, and its London-based European subsidiary, Credit Suisse Securities (Europe) Limited (“CSSEL”) resolved a wide-ranging bribery and fraud scheme...more
Court Reinstates Life Insurance Company's Fraud Claims Over Defunct Laboratory - A New Jersey state appeals court reinstated Aetna Life Insurance Company’s (Aetna) fraud claims against the minority owners of the now defunct...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
It is rare that a Chief Executive Officer (CEO) of a company pleads guilty to a criminal Foreign Corrupt Practices Act (FCPA) action. It is even rarer yet when that CEO runs a multi-billion dollar company. Yet that is what...more
In a landmark action on December 3, 2020, the Commodity Futures Trading Commission (“CFTC”) announced resolution of its first enforcement action involving foreign corruption by issuing an order and settling charges against...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
Recently we saw one of the most blatant cases of bribery and corruption brought by the Department of Justice (DOJ) in the form of a guilty plea by Sargeant Marine Inc. (Sargeant Marine), an asphalt company, related to...more
The Justice Department announced a guilty plea to FCPA charges by Sargeant Marine, Inc., a privately-owned company, based in Boca Raton, Florida. Sargeant Marine, an asphalt company, plead guilty to one count of conspiracy...more
A federal grand jury in the Eastern District of New York returned an indictment against Javier Aguilar, an oil trader at Vitol, an energy and commodity trading company, for his role in a five-year international bribery and...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