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Compliance Anti-Corruption FCPA Corporate Enforcement Policy (CEP)

Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory violations. ... more +
Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory violations.  In response to many corporate scandals evidencing rampant unethical business practices, many nations, including the United States, began passing strict regulatory frameworks aimed at curbing these abuses. Notable pieces of legislation in this area include the U.S. Foreign Corrupt Practices Act (FCPA), Sarbanes-Oxley (SOX), and the U.K. Bribery Act, to name a few. The foregoing statutes and the severe penalties often associated with them form the basis of many modern institutional compliance programs. less -
Morrison & Foerster LLP

DOJ Criminal Division Revises Its Corporate Enforcement Policy, Monitor Selection Policy, and Whistleblower Award Program

On May 12, 2025, the Criminal Division of the U.S. Department of Justice (DOJ) revised its Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP) and Corporate Whistleblower Awards Pilot Program (Whistleblower...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments: 2024 Year in Review

Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this special edition of our award-winning monthly Top 10 International Anti-Corruption Developments newsletter summarizes the most...more

WilmerHale

Global Anti-Bribery Year-in-Review: 2023 Developments and Predictions for 2024

WilmerHale on

Publicly announced Foreign Corrupt Practices Act (FCPA) enforcement activity in 2023 did not return to the levels seen a few years ago, as indicated by both the total number of cases against corporate and individual...more

Thomas Fox - Compliance Evangelist

The SAP FCPA Enforcement Action-Part 3: The Comeback

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

The Volkov Law Group

SAP’s Bribery Schemes — Systemic Corruption Around the Globe (Part II of III)

The Volkov Law Group on

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

Guidepost Solutions LLC

DOJ Maintains Interest in Bribery in Mexico and Latin America

Recent Department of Justice (“DOJ” or “Department”) activity on bribery in Mexico and Latin America sends a warning and provides a roadmap to companies doing business there.  By following the roadmap, companies may escape...more

The Volkov Law Group

DOJ and CFTC Close Out Slow FCPA Enforcement Year with $98 Million Resolution with Freepoint Commodities LLC (Part I of II)

The Volkov Law Group on

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

The Volkov Law Group

Justice Department Declines FCPA Prosecution Against Lifecore Biomedical Under Corporate Enforcement Policy

The Volkov Law Group on

The Justice Department has brought three corporate FCPA enforcement actions in 2023 (if you include the Ericsson DPA breach settlement).  With its recent announcement of a declination under the Corporate Enforcement Policy,...more

Morgan Lewis

Anti-Bribery And Corruption Survey Report

Morgan Lewis on

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

American Conference Institute (ACI)

[Event] 13th West Coast Forum on FCPA Enforcement and Compliance - June 14th - 15th, San Francisco, CA

Hosted by American Conference Institute, the 13th West Coast Forum on FCPA Enforcement and Compliance returns for another exciting year, providing the opportunity to connect with decision-makers from your industry, gather...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for January 2023

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

BakerHostetler

DOJ's Newly Revised Corporate Enforcement Policy Incentivizes Robust Compliance Programs, Cooperation and Remediation

BakerHostetler on

On Jan. 17, AAG Polite announced “the first significant changes” to the CEP since 2017. The policy revisions will apply to all corporate criminal matters handled by the Criminal Division and offer companies “new, significant,...more

Thomas Fox - Compliance Evangelist

HorrorFest 2020 Celebration: The Curse of Frankenstein and a Welcomed Safe Harbor

In this second edition of October HorrorFest 2020 celebration we consider the first Hammer film version of Frankenstein – The Curse of Frankenstein which was released in 1957. As Universal Studios had the copyright to the...more

Orrick, Herrington & Sutcliffe LLP

Takeaways from the Second Edition of the DOJ and SEC's FCPA Resource Guide (July 2020)

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

Jones Day

DOJ and SEC Publish Second Edition of the FCPA Resource Guide

Jones Day on

The Situation: On July 3, 2020, the Department of Justice ("DOJ") and the Securities and Exchange Commission ("SEC") published a second edition of the "Resource Guide to the Foreign Corrupt Practices Act," almost eight years...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

Top Five Department of Justice FCPA Enforcement Actions in 2019

Welcome to the 2020’s. The past decade helped shape both Foreign Corrupt Practices Act (FCPA) enforcement and corporate compliance programs. 2019 FCPA enforcements bore out many of the developments from the preceding years of...more

The Volkov Law Group

DOJ Tweaks FCPA Corporate Enforcement Policy

The Volkov Law Group on

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

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