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Compliance Enforcement Guidance Enforcement Actions

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 -
Latham & Watkins LLP

President Trump Issues Executive Order Pausing Foreign Corrupt Practices Act Enforcement at DOJ

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The order pauses new FCPA criminal cases, directs review of existing cases, and leaves open several questions, including implications for specific business sectors and civil enforcement....more

WilmerHale

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

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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

Hogan Lovells

DOJ sets forth new incentives for companies to self-disclose and cooperate

Hogan Lovells on

On January 17, 2023, the Department of Justice (DOJ) rolled out revisions to its Corporate Enforcement Policy (CEP) aimed at incentivizing companies to voluntarily self-disclose misconduct and to cooperate with government...more

The Volkov Law Group

DOJ Promoting Enforcement and Compliance Message

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Contrary to the often-repeated narrative, the Justice Department is transparent about its enforcement plans and compliance expectations.  Since the issuance of the FCPA Guidance in 2012, DOJ has continued to provide guidance...more

The Volkov Law Group

ABB – A Three-Time Loser – Settles FCPA Case for Bribery in South Africa for $315 Million (Part I of III)

The Volkov Law Group on

The Justice Department’s new Corporate Enforcement Policy and the heightened enforcement and compliance expectations were put to the test in its announcement of a $315 million settlement of bribery charges with ABB, a...more

Bracewell LLP

DOJ's Torpedoes Are in the Water: Be Your Own Monitor, or One will Be Appointed for You

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Last week, at a gathering of the nation’s top white collar criminal defense attorneys in Miami, Florida, Deputy Attorney General Lisa Monaco announced material changes to the way the Department of Justice will investigate,...more

WilmerHale

Global Anti-Bribery Year-in-Review: 2020 Developments and Predictions for 2021

WilmerHale on

As was true in many areas of the law, Foreign Corrupt Practices Act (FCPA) enforcement in 2020 - and anti-corruption enforcement more generally - was affected by the COVID-19 pandemic, but perhaps not as much as was initially...more

Proskauer - The Capital Commitment

FinCEN Explains What Guides Its Enforcement Decisions

On August 18, 2020, the Financial Crimes Enforcement Network (FinCEN), which is the primary regulator and administrator of the Bank Secrecy Act (BSA), issued a statement on enforcement of the BSA. The requirements of the BSA...more

A&O Shearman

Assistant Attorney General Brian A. Benczkowski Reviews FCPA Enforcement In 2019

A&O Shearman on

On December 4, 2019, Assistant Attorney General Brian A. Benczkowski provided a synopsis of FCPA enforcement in 2019 to the American Conference Institute’s International Conference on the Foreign Corrupt Practices Act....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

Jones Day

FINRA Clarifies When Credit for Extraordinary Cooperation Will Be Awarded in Investigations

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The Situation: In recent years, broker-dealers have been seeking further transparency from the Financial Industry Regulatory Authority ("FINRA") on what constitutes "extraordinary" cooperation with its investigations and when...more

Bracewell LLP

EPA Updates Its Audit Policy with "eDisclosure"

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On June 10, 2015, the U.S. Environmental Protection Agency hosted a webinar describing a plan to modernize the implementation of its April 11, 2000 Audit Policy. The plan – called eDisclosure – attempts to provide a...more

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