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Compliance Enforcement Actions Criminal Investigations

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 -
Thomas Fox - Compliance Evangelist

Daily Compliance News: July 25, 2025, The New Sheriff in Town Edition

Welcome to the Daily Compliance News. Each day, Tom Fox, the Voice of Compliance, brings you compliance-related stories to start your day. Sit back, enjoy a cup of morning coffee, and listen in to the Daily Compliance News....more

Vinson & Elkins LLP

Small Gains Yield Big Pain: How a $2,400 Profit Triggered an SEC, FBI, and FINRA Cavalry

Vinson & Elkins LLP on

On July 11, 2025, the Securities and Exchange Commission (“SEC” or the “Commission”) announced that it had settled an enforcement action against two individuals who were alleged to have engaged in insider trading. The SEC’s...more

Mintz - Antitrust Viewpoints

DOJ Antitrust Implements Whistleblower Incentive

On July 8, the Antitrust Division of the United States Justice Department (“DOJ Antitrust”) announced a Whistleblowers Rewards Program (“Program”) in partnership with another member of the Procurement Collusion Strike Force,...more

Fenwick & West LLP

DOJ Unpauses FCPA Enforcement with New Limits

Fenwick & West LLP on

On February 10, 2025, the president signed an executive order that paused investigation and enforcement of the FCPA for a period of 180 days, required the DOJ to review any existing FCPA investigation or prosecution, and to...more

Fox Rothschild LLP

“You Have the Right to Remain Silent” . . . Criminalization of Aviation Accidents

Fox Rothschild LLP on

In the second in our Aviation Symposium series of blog posts, we present the materials from the great panel we had discussing the criminalization of aviation accidents. We were fortunate enough to have renowned criminal...more

Womble Bond Dickinson

Compliance Still Matters: The Future of FCPA Enforcement

Womble Bond Dickinson on

On January 20, President Trump issued an Executive Order designating certain international cartels as Foreign Terrorist Organizations (FTOs) or Specially Designated Global Terrorists (SDGTs). ...more

Latham & Watkins LLP

UK and European Considerations: President Trump Pauses FCPA Enforcement

Latham & Watkins LLP on

The executive order halts new and existing foreign bribery investigations — but enforcement risk in the UK and Europe remains. On February 10, 2025, President Trump issued an executive order titled “Pausing Foreign...more

The Volkov Law Group

Episode 353 -- 2024 FCPA Enforcement and Compliance Review

The Volkov Law Group on

Can the DOJ’s commitment to holding individuals and corporations accountable under the FCPA survive the changing political climate in 2025? Will the push for innovation in corporate compliance programs be enough to maintain...more

The Volkov Law Group

McKinsey Company Pays $122 Million to Resolve FCPA Violations in South Africa (Part I of III)

The Volkov Law Group on

On December 5, 2024, DOJ announced a settlement with McKinsey and Company for $122 million for bribes paid to South African government officials to secure valuable consulting contracts....more

The Volkov Law Group

Raytheon’s False Claims Act Settlement (Part IV of IV)

The Volkov Law Group on

The Justice Department’s global settlement included a significant False Claims Act resolution, resulting in a second deferred prosecution agreement (“DPA”) for a three-year term. A criminal information was filed in the...more

The Volkov Law Group

Raytheon’s Defective Pricing Fraud and Resolution (Part II of IV)

The Volkov Law Group on

Raytheon’s criminal conduct cut across a variety of topics — it is difficult to imagine but Raytheon’s misconduct occurred in separate parts of the company, involving violations of different laws. Like most cases, I always...more

Fox Rothschild LLP

The Presumption of Innocence Podcast: Episode 47 - Fireside Chat With Bill Baroni and Jesse Eisinger

Fox Rothschild LLP on

Recorded at our 2024 White-Collar Symposium held in Philadelphia last month, this special episode dives into the landscape of white-collar criminal prosecution from the perspectives of Bill Baroni and Jesse Eisinger. Both...more

The Volkov Law Group

DOJ Issues New FCPA Declination: Boston Consulting Group Pays $14.4 Million

The Volkov Law Group on

The Justice Department is encouraging companies to voluntarily disclose criminal violations — “Come in and confess” and DOJ offers promises of a declination.  But even a declination comes with a requirement — the company has...more

The Volkov Law Group

Tracking FCPA Individual Enforcement

The Volkov Law Group on

While FCPA enforcement against companies has been relatively quiet this year, despite a strong beginning to the year — the SAP case for $220 million; and the Gunvor case for $661 million — DOJ has been pushing a number of...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

The Volkov Law Group

Episode 324 -- Third-Party Risks and Sanctions Compliance

The Volkov Law Group on

With the beginning of the “New FCPA” era coined by DOJ’s Deputy Attorney General Lisa Monaco, we now need to focus on third-party risk and sanctions enforcement. The law, the practice, and the risks are important and not just...more

Woods Rogers

Wax On, Wane Not: Corporate Investigations and Enforcement Actions are on the Rise at DOJ

Woods Rogers on

Every national election cycle, we are reminded that presidential administrations drive the trajectory of white-collar civil and criminal enforcement priorities. Halfway through President Biden’s first term, in 2022, Attorney...more

Fox Rothschild LLP

The Presumption of Innocence Podcast: Episode 34 - A Conversation With Jesse Eisinger, Author of 'The Chickenshit Club: Why the...

Fox Rothschild LLP on

In a single decade, the prosecutions of those accused of white-collar crime underwent a radical transformation. This thought-provoking episode will take you back in time to explore the DOJ's approach in the early 2000s Enron...more

The Volkov Law Group

Episode 317 -- A Deep Dive into the Trafigura FCPA Settlement

The Volkov Law Group on

On the heels of the Gunvor FCPA settlement for $661 million, DOJ announced its settlement with Trafigura, the latest commodities trading company to fall under DOJ's FCPA Sweep against the industry.  Trafigura joined the list...more

Thomas Fox - Compliance Evangelist

The Gunvor FCPA Enforcement Action: Part 3-the Discounted Fine

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

White & Case LLP

DOJ Doubles Down on Warnings Against AI Misuse

White & Case LLP on

In February 2024, we published an alert concerning the increase in regulatory attention to "AI washing," or making unfounded claims regarding artificial intelligence ("AI") capabilities. Notably, on February 14, 2024,...more

Mayer Brown

Teeth Can Bite: Towards Harmonized Rules on EU Sanctions Criminal Enforcement

Mayer Brown on

On March 12, 2023, the European Parliament ("EP") formally endorsed the adoption of a Directive defining criminal offences and penalties for the violation of European Union ("EU") restrictive measures, colloquially known as...more

Thomas Fox - Compliance Evangelist

Ten Top Lessons from Recent FCPA Settlements-Lesson No. 2, the Need for Speed

Over the past 15 months the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) has made clear through three Foreign Corrupt Practices Act (FCPA) enforcement actions and speeches, their priorities in...more

Morrison & Foerster LLP

MoFo's 2023 FCPA Year in Review

Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, our Foreign Corrupt Practices Act (FCPA) Year In Review provides quick, visual representations of key trends in FCPA enforcement over...more

BCLP

FCA publishes its 2022/23 Annual Report and Enforcement data

BCLP on

The FCA released its 2022/23 Annual Report last week together with data on its key enforcement trends. We consider below some of the key takeaways....more

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