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Corruption Banking Sector Foreign Corrupt Practices Act (FCPA)

Thomas Fox - Compliance Evangelist

10 For 10: Top Compliance Stories For the Week Ending June 7, 2025

Welcome to 10 For 10, the podcast which brings you the week’s Top 10 compliance stories in one podcast each week. Tom Fox, the Voice of Compliance brings to you, the compliance professional, the compliance stories you need to...more

The Volkov Law Group

Credit Suisse Settles Multi-Jurisdiction Bribery and Fraud Case for $547 Million (Part I of II)

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Credit Suisse Group AG (“Credit Suisse”), a global financial institution, and its London-based European subsidiary, Credit Suisse Securities (Europe) Limited (“CSSEL”) resolved a wide-ranging bribery and fraud scheme...more

Foodman CPAs & Advisors

Financial Institutions and the FCPA

The Foreign Corrupt Practices Act (FCPA) prohibits payment of bribes to foreign officials to assist with obtaining or retaining business.  It requires companies whose securities are listed in the US to maintain books 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

Thomas Fox - Compliance Evangelist

Tribute to the Fantastic Four: Part I- Four Questions for Goldman Sachs

David Crow, writing in a Financial Times (FT) article, entitled “Key questions for Goldman Sachs about Malaysian scandal”, said that Goldman Sachs was scheduled to meet with the Department of Justice (DOJ) this week. Crow...more

Thomas Fox - Compliance Evangelist

The Credit Suisse FCPA Enforcement Action: Part III – The Result and Going Forward

Last week Credit Suisse Group AG (CSAG) and Credit Suisse (Hong Kong) Limited (CSHK), a subsidiary of CSAFG, settled a Foreign Corrupt Practices Act (FCPA) enforcement action for just over $77 million for the illegal hiring...more

Thomas Fox - Compliance Evangelist

The Credit Suisse FCPA Enforcement Action: Part II – The (Very) Bad Facts

Last week Credit Suisse Group AG (CSAG) and Credit Suisse (Hong Kong) Limited (CSHK), a subsidiary of CSAFG, settled a Foreign Corrupt Practices Act (FCPA) enforcement action for just over $77 million for the illegal hiring...more

Thomas Fox - Compliance Evangelist

The Credit Suisse FCPA Enforcement Action: Part I – Background

Last week Credit Suisse Group AG (CSAG) and Credit Suisse (Hong Kong) Limited (CSHK), a subsidiary of CSAFG, settled a Foreign Corrupt Practices Act (FCPA) enforcement action for just over $77 million for the illegal hiring...more

The Volkov Law Group

Lessons Learned from Credit Suisse Corrupt Hiring Scheme and FCPA Settlement (Part II of II)

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Credit Suisse has joined the ranks of other banks and companies that have settled FCPA violations involving hiring of government officials’ relatives in exchange for business benefits, including JPMorgan Chase; BNY Mellon,...more

The Volkov Law Group

Credit Suisse Pays $76 Million for Sons and Daughters FCPA Violations in China (Part I of II)

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Credit Suisse Group AG and its Hong Kong subsidiary settled FCPA charges with the Justice Department and the Securities and Exchange Commission. The Justice Department announced that Credit Suisse’s Hong Kong subsidiary...more

Holland & Knight LLP

Recent Debarments Highlight Growing Risk of Sanctions By Multilateral Development Banks

Holland & Knight LLP on

• Companies that operate globally face substantial risks associated with activities funded by multilateral development banks (MDBs). • Several recent debarment actions by the World Bank highlight those risks. • To...more

The Volkov Law Group

It Takes a Village . . . To Commit Bribery

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A company that commits bribery has to undergo a soul-searching examination of its operations, from top to bottom. Bribery violations come in all shapes and forms – systemic violations like Siemens, Daimler and other...more

Thomas Fox - Compliance Evangelist

Why Compliance Must Manage Risk

What is risk to your company? In the anti-corruption world, it is conduct which might violate the Foreign Corrupt Practices Act (FCPA), UK Bribery Act, Brazilian Clean Companies Act or one of the other internationally focused...more

The Volkov Law Group

Aggressive Remediation: Embraer and JP Morgan

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There is no question that the Justice Department has raised compliance program expectations in a number of areas. Whatever you may think about the efficacy or fairness of the FCPA Pilot Program, the Justice Department has...more

Thomas Fox - Compliance Evangelist

JPMorgan Sons and Daughters FCPA Enforcement Action, Part II

Today I will consider the superior result achieved by JPM in its FCPA resolution. Not only did it receive a 25% discount off the bottom of the US Sentencing Guidelines fine range but it received a NPA and not even a Deferred...more

Thomas Fox - Compliance Evangelist

Wells Fargo Week: Part V – Compliance is the Answer

I want to end this week’s review of the Wells Fargo scandal by considering what is at issue and what is at stake in this imbroglio. Unlike a Foreign Corrupt Practices Act (FCPA) violation, Wells Fargo paid the relatively...more

Thomas Fox - Compliance Evangelist

Three Key Questions to Ask in Hiring of Family Members of Foreign Officials

One of the top academic commentators in the anti-corruption space is Matthew C. Stephenson, co-founder of the Global Anticorruption Blog. I was intrigued by Stephenson’s piece, entitled “Does an FCPA Violation Require a Quid...more

Thomas Fox - Compliance Evangelist

Froome Ends Tour With Win; JP Morgan to End Sons and Daughters Case?

I begin today’s post with a tip of the (cycling) helmet to Englishman Chris Froome who yesterday won his third Tour de France championship. Froome overcame a great many obstacles, not the least of which was being involved a...more

K&L Gates LLP

Focus on Corruption: Myanmar - A New Beginning?

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Historically, Myanmar has not been known as a country with a focus on anti-corruption and anti-money laundering. In 2015, the Frankfurt-based Transparency International ranked the country as one of the most corrupt places to...more

Thomas Fox - Compliance Evangelist

Will the FCPA Go Down Under (again)?

We do not often have the chance to go ‘down under’ at the FCPA Compliance and Ethics Blog. However, there is a case brewing that may have some Foreign Corrupt Practices Act (FCPA) implications as well as Australian...more

Thomas Fox - Compliance Evangelist

Reflections on the Hitachi FCPA Enforcement Action

Earlier this week, the Securities and Exchange Commission (SEC) announced resolution of a Foreign Corrupt Practices Act (FCPA) enforcement action involving the Hitachi Ltd (Hitachi). There were several interesting aspects to...more

The Volkov Law Group

Hiring Practices: A New or Old FCPA Compliance Challenge?

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Contrary to the opinion of many in the FCPA space, the BNY Mellon settlement and the looming actions against six major financial institutions for hiring practices is not a big shock or surprise. The SEC is not raising a new...more

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