Compliance Perspectives: Compliance Challenges in India
FCPA Compliance Report-Episode 350, Linda Justice and Her Nancy Drew Approach
Day 16 of One Month to More Effective Continuous Improvement-Voluntary Monitoring
Day 5 of One Month to Better Investigations and Reporting-the Board’s Investigation Protocol
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
On October 28, 2021, Deputy Attorney General Lisa Monaco announced revised Department of Justice (DOJ) guidance on corporate monitors. Going forward, prosecutors are free to require the imposition of a corporate monitor when...more
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
On December 6, 2019, Telefonaktiebolaget LM Ericsson (Ericsson or the Company), resolved long-running investigations by the U.S. Department of Justice (DOJ) and the U.S. Securities and Exchange Commission (SEC) into the...more
Enforcement authorities throughout the United States and the Americas continue to aggressively investigate fraud and corruption across the region in the third quarter of 2019. Below, we highlight some recent developments and...more
Guidance sets out the SFO’s expectations for investigations but leaves open questions, particularly for cross-border investigations. On 6 August 2019, the UK Serious Fraud Office (SFO) issued its much-anticipated Corporate...more
The month of June, 2019, closed out one of the most interesting half-years in the Foreign Corrupt Practices Act (FCPA) realm....more
As the annual ABA White Collar Crime Conference wrapped up in New Orleans last Friday night, the Department of Justice released the latest updates to its FCPA Corporate Enforcement Policy. The key changes to the policy...more
Despite predictions of a slow-down in enforcement under the Trump administration—and indications that enforcement in some areas has decreased in the past year1—2018 was yet again an active year for FCPA enforcement. The year...more
In a speech delivered on Thursday, Nov. 29, 2018, Deputy Attorney General Rod Rosenstein described important changes to DOJ policies for awarding cooperation credit in corporate investigations. These changes have been...more
There are multiple areas in the Department of Justice’s Evaluation of Corporate Compliance Programs which intersect with the area of continuous improvement. In addition to Prong 9. Continuous Improvement, Periodic Testing and...more
Many companies have an investigation protocol in place when a potential Foreign Corruption Practices Act (FCPA) or other legal issue arises? However, many Boards of Directors do not have the same rigor when it comes to an...more
The Justice Department’s hiring of Hui Chen as the new Compliance Counsel is an important development in DOJ’s prosecution of corporate defendants. It is not clear yet what impact Ms. Chen will have. At a recent event at NYU,...more