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Corporate Counsel Foreign Corrupt Practices Act (FCPA) Internal Controls

Morgan Lewis

DOJ FCPA Declination Points to Continuation of Policies and Importance of Robust Compliance

Morgan Lewis on

An August 7, 2025 declination agreement published by the US Department of Justice’s (DOJ’s) Fraud Section—and the first bribery DOJ resolution of President Trump’s second term—provides initial insights into declinations under...more

The Volkov Law Group

John Deere Reaches $9.9 Million Settlement with SEC over FCPA Violations

The Volkov Law Group on

The U.S. Securities and Exchange Commission (“SEC”) recently instituted proceedings against Deere & Company (“John Deere”), a leading global manufacturer of agricultural and heavy machinery, for multiple violations of the...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for November 2023

Morrison & Foerster LLP on

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

Bradley Arant Boult Cummings LLP

Philips Agrees to Pay $62M to Settle FCPA Books-and-Records Violations from Efforts to Win Chinese Contracts

Koninklijke Philips N.V., a global medical technology manufacturer, recently agreed to pay over $62 million to resolve a Foreign Corrupt Practices Act (FCPA) enforcement action with the Securities and Exchange Commission...more

The Volkov Law Group

Oracle’s FCPA Violations: A Lesson in Managing Third-Party Distributor Risks (Part II of II)

The Volkov Law Group on

Oracle’s SEC settlement for $23 million underscores the power of the FCPA provisions mandating effective internal controls and accurate books and records.  As everyone knows, these provisions can be applied to a wide-range of...more

American Conference Institute (ACI)

[Event] FCPA & Anti-Corruption for the Life Sciences Industry - July 21st - 22nd, Boston, MA

ACI is excited to welcome you back in-person to the 14th Advanced Forum on FCPA & Anti-Corruption for the Life Sciences Industry, taking place on July 21–22, 2022 in Boston! Legal and compliance professionals from...more

Society of Corporate Compliance and Ethics...

[Virtual Event] Global Compliance Updates - November 2nd - 3rd, 5:55 pm - 8:15 pm GST

Compliance teams looking to stay ahead of the changing landscape need to be up to date on the latest developments. Join us for Global Compliance Updates in collaboration with the DIFC Academy, on 2–3 November 2021. This...more

The Volkov Law Group

DOJ Hits Beam Suntory with FCPA Settlement for $19.5 Million (Part I of II)

The Volkov Law Group on

Beam Suntory, a global producer and distributor of distilled beverages, settled its FCPA case with DOJ for $19.5 million for bribes paid in India.  The DOJ settlement follows an SEC FCPA settlement for $8 million announced...more

The Volkov Law Group

World Acceptance Corporation Settles FCPA Charges with the SEC for $21.7 Million

The Volkov Law Group on

World Acceptance Corporation (“WAC”), a US-based consumer loan company, agreed to pay the SEC $21.7 million for FCPA violations in Mexico.  WAC’s cited violations covered the full gamut of FCPA violations, including bribery...more

White & Case LLP

DOJ Updates Guidance on Evaluation of Corporate Compliance Programs

White & Case LLP on

On June 1, 2020, the US Department of Justice ("DOJ") published an updated version of its guidance on the "Evaluation of Corporate Compliance Programs" (the "Guidance"), which was first published in February 2017. When...more

A&O Shearman

SEC Reaches $8.8 Million Settlement With Pharmaceutical Company To Resolve Allegations Of FCPA Violations

A&O Shearman on

On February 28, 2020, the U.S. Securities and Exchange Commission (“SEC”) announced a settled administrative proceeding with an Ohio-based pharmaceutical company, Cardinal Health, Inc. (“Cardinal”) over alleged violations of...more

Latham & Watkins LLP

Current Developments in the US: White-Collar Enforcement and trends for 2020

Latham & Watkins LLP on

In the following article we will discuss the current developments and trends for 2020 and outline what EU-based companies with a US presence should look out for in 2020 regarding US white-collar and compliance trends in the...more

Foley Hoag LLP - White Collar Law &...

White Collar Year in Preview: Anti-Corruption Trends in 2020

Editors’ Note: This is the third in our start-of-year series examining important trends in white collar law and investigations in the coming year. Our previous entry discussed healthcare fraud in 2020. Up next: a look at...more

Thomas Fox - Compliance Evangelist

Top SEC Enforcement Actions from 2019

Yesterday, I considered five Department of Justice (DOJ) Foreign Corrupt Practices Act (FCPA) enforcement actions. Today, I want to look at key FCPA enforcement actions by the Securities and Exchange Commission (SEC)....more

Thomas Fox - Compliance Evangelist

Billion Dollar Baby: Ericsson FCPA Enforcement Action – Part 3: Internal Control Failures

Last week the Justice Department (DOJ) announced a resolution of the long standing Foreign Corrupt Practices Act (FCPA) enforcement action involving Telefonaktiebolaget LM Ericsson (Ericsson), a multinational networking and...more

Thomas Fox - Compliance Evangelist

Walmart FCPA Enforcement Action: Part 1 – Introduction

The big one finally is resolved. The long-awaited Walmart Inc. (Walmart) Foreign Corrupt Practices Act (FCPA) enforcement action was announced yesterday. This massive case came in with multiple documents, a long list of...more

Wilson Sonsini Goodrich & Rosati

Telefônica Brasil Case Reinforces Risks of Gifts and Hospitality Involving Foreign Officials

On May 9, 2019, Telefônica Brasil agreed to pay a US$4.13 million civil fine to settle U.S. Securities and Exchange Commission charges for violations of the internal accounting controls and recordkeeping provisions of the...more

Thomas Fox - Compliance Evangelist

The Updated Evaluation of Corporate Compliance Programs – Guidance Document: Part 4 – Effective Training

We are in an exploration of the recently released Evaluation of Corporate Compliance Programs – Guidance Document (2019 Guidance), which was announced (ECI speech) by Assistant Attorney General Brian Benczkowski at the Ethics...more

Jones Day

FCPA 2018 Year In Review

Jones Day on

Under the second year of the Trump Administration, the biggest story was the increase of corporate declinations one year after the DOJ adopted a permanent FCPA policy incentivizing self-disclosure, cooperation, and...more

The Volkov Law Group

2018 FCPA Year in Review: The More Things Change, The More They Stay the Same

The Volkov Law Group on

Happy New Year! Another year is in the books for FCPA enforcement and compliance. The headline for this past year (like many other years) is/was – The more things change, the more they stay the same....more

Holland & Knight LLP

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

Holland & Knight LLP on

• 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

A&O Shearman

Medical Device Manufacturer Enters Into Second FCPA Settlement In Five Years With SEC

A&O Shearman on

On September 28, 2018, the Securities and Exchange Commission (“SEC”) announced a settlement with a Michigan-based manufacturer and distributor of medical devices, over allegations that the company had violated the books and...more

Thomas Fox - Compliance Evangelist

The NPA; The Petrobras FCPA Enforcement Action: Part III

This blog post concludes my multi-part exploration of the Petróleo Brasileiro S.A. – Petrobras (Petrobras) Foreign Corrupt Practices Act (FCPA) enforcement action. Today we consider the stunning result achieved by Petrobras –...more

The Volkov Law Group

Stryker Suffers “Strike Two” and Settles SEC FCPA Case

The Volkov Law Group on

Stryker Corporation has suffered a second FCPA enforcement action, and will now bear the stigma of FCPA “recidivist.” In reaching a settlement with the SEC and agreeing to pay a $7.8 million civil penalty, Stryker will now...more

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