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Corruption Compliance Criminal Prosecution

WilmerHale

UK, French, and Swiss Enforcement Authorities Announce New Alliance

WilmerHale on

Anti-bribery and corruption agencies in the UK, France and Switzerland today announced a shared commitment to tackling international bribery and corruption, by way of a new taskforce intended to strengthen collaboration....more

Whiteford

Client Alert: Attorney General Bondi Changes Direction on FCPA and FARA Prosecutions

Whiteford on

On her first day in office, Attorney General Pam Bondi announced several changes to the standards governing the exercise of prosecutorial discretion, charging decisions, plea negotiations and sentencing recommendations. Two...more

Skadden, Arps, Slate, Meagher & Flom LLP

Annual Report Highlights France’s Financial Crime Enforcement and International Cooperation

Ten years after its establishment, France’s National Financial Prosecutor’s Office (Parquet National Financier or PNF) has released its 2024 annual report (Report),1 showcasing a year of consolidation and innovation in the...more

Vedder Price

Changed Focus of FCPA Actions Under Trump Executive Order

Vedder Price on

On February 5, 2025, newly appointed U.S. Attorney General Pam Bondi issued a memorandum titled “Total Elimination of Cartels and Transnational Criminal Organizations” (the February 5 Memorandum), which outlined a broad...more

Vinson & Elkins LLP

Future of FCPA Enforcement Uncertain (For Now) as New Administration Revamps the Law Enforcement Toolkit

Vinson & Elkins LLP on

Among the drumbeats of rapid pronouncements and policy shifts since January 20, 2025, the Trump Administration recently issued a 180-day pause on new investigations and enforcement actions involving the U.S. Foreign Corrupt...more

Womble Bond Dickinson

DOJ Narrows FCPA Enforcement Focus

Womble Bond Dickinson on

Attorney General (AG) Pam Bondi has issued a directive that both: (1) effectively shifts the DOJ’s FCPA enforcement focus towards those cases related to foreign bribery involving cartels and transnational criminal...more

Morgan Lewis

Newly Confirmed AG Pam Bondi Issues Directive Limiting Scope of FCPA Enforcement

Morgan Lewis on

Newly Appointed US Attorney General Pam Bondi issued a directive shifting the focus of Foreign Corrupt Practices Act investigations and cases away from those that do not involve criminal operations of cartels and...more

The Volkov Law Group

FCPA 2024 Enforcement — Bribery Schemes and Compliance Reminders (Part II of III)

The Volkov Law Group on

Criminals can be creative — that is a true statement but essentially FCPA criminals have to embrace a variety of well-established techniques to accomplish a straight-forward goal — steal money from the company to funnel...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments: 2024 Year in Review

Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this special edition of our award-winning monthly Top 10 International Anti-Corruption Developments newsletter summarizes the most...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for December 2024

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

The Volkov Law Group

DOJ and SEC Close 2024 with FCPA Enforcement Action Against AAR Corp; DOJ and SEC Announces Resolution with Deepak Sharma, CEO of...

The Volkov Law Group on

The Justice Department and the SEC finished 2024 with a coordinated resolution of criminal and civil FCPA charges against AAR Corporation, an Illinois-based provider of aviation products and services. In addition, DOJ...more

The Volkov Law Group

DOJ Indicts Indian Billionaire and Seven Other Individuals for Bribery and Fraud Scheme Involving Payments to Indian Government...

The Volkov Law Group on

In a far-reaching criminal case, in November 2024, the Justice Department unsealed a complex, five-count indictment in the Eastern District of New York charging eight defendants, including Gautam S. Adani, Sagar R. Adani and...more

The Volkov Law Group

McKinsey Company's Bribery Scheme - A Familiar Pattern in South Africa (Part II of III)

The Volkov Law Group on

The McKinsey FCPA case follows several other significant cases involving South Africa.  ABB and SAP resolved FCPA cases involving bribes in South Africa; on the SEC front, Gartner resolved a bribery case involving South...more

The Volkov Law Group

Lessons Learned from the Telefónica FCPA Settlement (Part III of III)

The Volkov Law Group on

The Justice Department’s record of FCPA enforcement in 2024 has been disappointing.  With all of the hoopla and pronouncements surrounding the global war against corruption, DOJ suggested that enforcement in 2023 and 2024...more

The Volkov Law Group

TD Bank’s Rotten Corporate Culture — From its Store-Level Operations to its Board’s Audit Committee (Part IV of IV)

The Volkov Law Group on

TD Banks’ complete compliance disaster was reflected in every aspect of TD Bank’s business and compliance operations. It is not surprising that TD Bank’s deficient BSA and AML compliance program was known by its Board of...more

Fox Rothschild LLP

The Presumption of Innocence Podcast: Episode 47 - Fireside Chat With Bill Baroni and Jesse Eisinger

Fox Rothschild LLP on

Recorded at our 2024 White-Collar Symposium held in Philadelphia last month, this special episode dives into the landscape of white-collar criminal prosecution from the perspectives of Bill Baroni and Jesse Eisinger. Both...more

Thomas Fox - Compliance Evangelist

The Bre-X Mining Scandal, Part 3: Why Was No One Prosecuted

In the annals of corporate fraud, few scandals match the magnitude of the Bre-X mining affair. For compliance professionals, the lessons from this incident resonate deeply, not just because of the scale of the deception but...more

Thomas Fox - Compliance Evangelist

Lessons on Ongoing Monitoring and Continuous Improvement from Star Trek: Spectre of the Gun

Last month, I wrote a blog post on the tone at the top, exemplified in Star Trek’s Original Series episode, Devil in the Dark. Based on the response, some passionate Star Trek fans are out there. I decided to write a series...more

The Volkov Law Group

DOJ Implements New Corporate Whistleblower Plan to Accelerate Corporate Criminal Enforcement (Part I of II)

The Volkov Law Group on

DOJ is feeling the heat.  Corporate criminal enforcement numbers are down. in fairness, DOJ has been pushing individual criminal enforcement as an effective deterrent to corporate misconduct.  Criminal prosecutions, when done...more

The Volkov Law Group

District Court Rejects Challenges to ITAR Criminal Charges

The Volkov Law Group on

On July 9, 2024, District Judge David Hale in Kentucky denied motions to dismiss and motions to suppress filed by four defendants against a criminal case involving ITAR charges for illegal exports of sensitive,...more

Womble Bond Dickinson

Supreme Court Resolves Circuit Split and Finds Federal Gratuities Inapplicable to State and Local Officials

Womble Bond Dickinson on

On June 26, 2024, the U.S. Supreme Court issued an opinion in a public corruption case that could have a lasting impact on how the U.S. Government prosecutes corruption and procurement fraud cases involving state and local...more

Fox Rothschild LLP

The Presumption of Innocence Podcast: Episode 34 - A Conversation With Jesse Eisinger, Author of 'The Chickenshit Club: Why the...

Fox Rothschild LLP on

In a single decade, the prosecutions of those accused of white-collar crime underwent a radical transformation. This thought-provoking episode will take you back in time to explore the DOJ's approach in the early 2000s Enron...more

The Volkov Law Group

Lessons-Learned from the Trafigura FCPA Settlement (Part III of III)

The Volkov Law Group on

The Justice Department is rightly trumpeting its successful sweep of the commodities trading industry.  DOJ’s success is reflected in its six separate corporate resolutions and 20 individual convictions, resulting in over...more

The Volkov Law Group

Trafigura’s Bribery Scheme: Clandestine Meetings, 3rd Parties and Shell Companies (Part II of III)

The Volkov Law Group on

Trafigura’s bribery scheme resembles the same schemes implemented by its significant competitors — Vitol, Glencore, Gunvor.  At the core of the conduct, Petrobras and Brazilian government officials collected bribes in...more

The Volkov Law Group

Trafigura Joins the FCPA Enforcement Club: Pleads Guilty and Pays Over $126 Million for Bribery Violations in Brazil (Part I of...

The Volkov Law Group on

On the heels of the Gunvor FCPA settlement for $661 million, DOJ announced its settlement with Trafigura, the latest commodities trading company to fall under DOJ’s FCPA Sweep against the industry.  Trafigura joined the list...more

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