News & Analysis as of

Cooperation Internal Controls

Epiq

The New DOJ Position on Self-Disclosure Demands High-Functioning Compliance

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In remarks to an industry group, Matthew R. Galeotti, head of the Department of Justice (DOJ) Criminal Division, emphasized that companies may avoid criminal resolutions if they voluntarily self-disclose misconduct, fully...more

Latham & Watkins LLP

Landmark Bank Secrecy Act Resolution Signals Increasing Focus on Banks’ Anti-Money Laundering Compliance

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Enforcement agencies urge investment in compliance programs. On October 10, 2024, the Department of Justice (DOJ) announced plea agreements with TD Bank N.A. (TDBNA) and its parent company, TD Bank US Holding Company...more

American Conference Institute (ACI)

[Event] 40th International Conference on the FCPA - November 28th - 30th, National Harbor, MD

Hosted by American Conference Institute, the 40th International Conference on the FCPA returns for another exciting year with curated programming that shines a global spotlight on anti-corruption compliance challenges,...more

Society of Corporate Compliance and Ethics...

[Virtual Event] Corporate Compliance Enforcement Conference - July 25th, 9:00 am - 4:45 pm CT

Is Your Compliance Program Designed for the Current Enforcement Landscape? Data protection, anti-corruption, antitrust, supply chains, economic sanctions and even the software employees use to communicate are all subjects...more

Skadden, Arps, Slate, Meagher & Flom LLP

CFTC Issues New Enforcement Guidance on Cooperation Recognition in Its Orders

On October 29, 2020, the Commodity Futures Trading Commission (CFTC) Division of Enforcement (Division) issued a memorandum (Guidance) providing guidance for Division staff to follow when recommending the recognition of an...more

The Volkov Law Group

Avanir Pharmaceuticals Pays More than $108 Million to Settle Kickback Violations

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Just to repeat myself – pharmaceutical and medical device firms face extraordinary risks of enforcement under the False Claims Act.  While everyone likes to write and focus on FCPA or anti-corruption risks for global drug and...more

Thomas Fox - Compliance Evangelist

Flame On-Tribute to the Fantastic Four: Part II – Four Issues from the FCPA Corporate Enforcement Policy

Yesterday, I considered four questions which the Department of Justice (DOJ) may ask Goldman Sachs. Today I want to consider what the company must show under the FCPA Corporate Enforcement Policy....more

Holland & Knight LLP

Petrobras Agrees to Pay More Than $1.8 Billion for Facilitating FCPA Violations

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• Four years ago, Brazilian authorities began Operation Car Wash, a wide-ranging and still ongoing corruption and money laundering investigation that has spanned 11 countries. • The fallout continues with a recent U.S....more

Thomas Fox - Compliance Evangelist

Farewell to V.S. Naipaul and Creating Priorities in Your Compliance Program

V.S. Naipaul died last week. He was a Trinidadian born grandson of Indian indentured servants sent to the island to work in the sugar plantations. From those humble beginnings, Naipaul rose to the heights of the literary...more

Latham & Watkins LLP

SEC Investigations: A Guide for Public Company Directors, Officers, and In-House Counsel

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Even public companies with a strong code of conduct, an exemplary tone at the top, robust internal controls, and a culture of compliance may face allegations of misconduct that can lead to an investigation by the Division of...more

Thomas Fox - Compliance Evangelist

Declinations and Profits Disgorgement – It Was There All Along

Last week there were two declinations issued by Department of Justice (DOJ) for Foreign Corrupt Practices Act (FCPA) matters. The matters involved two Texas based, privately held companies. The first was HMT LLC (HMT) which...more

Snell & Wilmer

The Foreign Corrupt Practices Act’s One-Year “Pilot Program” Nears The Halfway Mark

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The Foreign Corrupt Practices Act (“FCPA”) prohibits both United States and foreign corporations and nationals from offering or paying, or authorizing the offer or payment, of anything of value to a foreign government...more

Fenwick & West LLP

Securities Litigation and Enforcement Newsletter

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SEC Enforcement Trends for 2016 - Welcome to the latest edition of Fenwick and West’s Securities Litigation and Enforcement Newsletter. In this newsletter, we look at SEC enforcement trends for 2016, starting with a...more

WilmerHale

Foreign Corrupt Practices Act Alert

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Busy Q1 Yields Several Significant FCPA Resolutions - Overview - On February 19, during the US Securities and Exchange Commission’s (SEC) annual “SEC Speaks” conference, Kara Brockmeyer, Chief of the SEC’s FCPA...more

McDermott Will & Emery

Focus on China - October 2015

McDermott Will & Emery on

Welcome to the third issue of Focus on China Compliance for 2015. According to the FCPA Blog’s October 2015 Corporate Investigations List, China leads the countries reported to be involved in FCPA investigations with 29...more

Morrison & Foerster LLP - Structured Products

Structured Thoughts: News for the financial services community, Volume 6, Issue 6

U.S. Structured Warrant Programs: Introduction - U.S. and non-U.S. banks have offered structured warrants in the U.S. to address the needs of both institutional and high-net worth investors. This article will...more

Proskauer - Corporate Defense and Disputes

Louis Berger International Pays $17 Million Penalty for FCPA Violation

On July 17, 2015, Louis Berger International, Inc., a New Jersey-based construction management company, entered into a deferred prosecution agreement (DPA) with the Department of Justice under which it agreed to pay a $17.1...more

Thomas Fox - Compliance Evangelist

FCPA Compliance and Ethics Report-Episode 165-BHP FCPA Enforcement and Lessons Learned for the Compliance Practitioner

In this episode I review the BHP Billiton FCPA enforcement action brought by the Securities and Exchange Commission. I review the underlying facts and provide some lessons learned for the compliance practitioner. The key...more

Katten Muchin Rosenman LLP

Former Olympic Games Sponsor Settles With SEC for $25 Million Over FCPA Violations

On May 20, BHP Billiton Ltd. and BHP Billiton Plc (BHPB), a global resources company that sponsored the 2008 Beijing Summer Olympic Games, settled Securities and Exchange Commission charges of Foreign Corrupt Practices Act...more

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