News & Analysis as of

Corruption Compliance Government Investigations

Latham & Watkins LLP

President Trump Issues Executive Order Pausing Foreign Corrupt Practices Act Enforcement at DOJ

Latham & Watkins LLP on

The order pauses new FCPA criminal cases, directs review of existing cases, and leaves open several questions, including implications for specific business sectors and civil enforcement....more

WilmerHale

2021 Global Anti-Bribery Year-in-Review

WilmerHale on

In 2021, the number of publicly resolved Foreign Corrupt Practices Act (FCPA) cases was relatively low compared with previous years, but there were numerous interesting developments, and enforcement activity going forward...more

Vinson & Elkins LLP

[Webinar] Corruption in the Time of COVID-19 - September 16th, 8:00 am - 9:00 am CT

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While GDP and worldwide economies shrink under the continuing impact of COVID-19, government budgets have expanded to support healthcare responses to the pandemic and social-welfare in response to growing unemployment and...more

Holland & Knight LLP

Lessons Learned from the Airbus Anti-Corruption Settlements

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In late January 2020, Airbus agreed to pay nearly $4 billion and to take a number of remedial measures in order to resolve alleged corruption violations with the French National Financial Prosecutor's Office (PNF), the United...more

King & Spalding

Q3 2019: Latin America Enforcement Review

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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

The Volkov Law Group

Juniper Networks Settles FCPA Violations with SEC for $11.7 Million

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Juniper Networks agreed to pay the SEC $11.7 million to settle FCPA violations for conduct occurring in Russia and China. Under the settlement, Juniper Networks agreed to disgorgement of $4 million, a $6.5 million civil...more

Thomas Fox - Compliance Evangelist

TechnipFMC FCPA Enforcement Action-Lessons Learned

We continue our exploration of the TechnipFMC Foreign Corrupt Practices Act (FCPA) enforcement action by considering the actions taken by the company (or both separately before their merger) in response to their FCPA...more

King & Spalding

H1 2019: Latin America Enforcement Observations

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The U.S. Justice Department, the U.S. Securities and Exchange Commission, and their enforcement partners throughout Latin America remain focused on actively investigating corruption activities and bringing enforcement actions...more

Polsinelli

DOJ Implements Formal Policies for Cooperation Credit in False Claims Act Cases

Polsinelli on

Last month, Polsinelli highlighted a recent update to the Department of Justice (DOJ) Evaluation of Corporate Compliance Programs, which detailed how DOJ will evaluate the effectiveness of corporate compliance programs in the...more

The Volkov Law Group

OFAC Enforcement: The Epsilon Case and Third Party Risks

The Volkov Law Group on

The Department of Treasury’s Office of Foreign Asset Control (“OFAC”) recently announced the settlement of the Epsilon enforcement action. This case requires a theme song and there is none better than Trucking from Grateful...more

Thomas Fox - Compliance Evangelist

Responding to Investigative Findings

Most companies understand a the need for an investigative protocol or bringing in experienced investigative counsel should a substantive Foreign Corrupt Practices Act (FCPA) allegation arise. However what is not as well known...more

The Volkov Law Group

DOJ Continues Run on Individual FCPA Criminal Prosecutions

The Volkov Law Group on

The Department of Justice announced criminal FCPA charges against two individuals in connection with bribery payments to foreign officials in Chad and Uganda. The Justice Department’s announcement occurred on the heels of...more

Thomas Fox - Compliance Evangelist

Hui Chen-Propelling a New Level of Thinking on Compliance

Last week Matt Kelly scored the first interview with the Department of Justice’s (DOJ) former Compliance Counsel, Hui Chen after she left the DOJ. Kelly posted it on his Radical Compliance podcast site and its available on...more

Thomas Fox - Compliance Evangelist

Does Obeying the FCPA Hurt Your Recruiting?

Imagine your company has gone through a Foreign Corrupt Practices Act (FCPA) investigation. As you near the end of the investigative phase and move into the enforcement phase, you tell the government that you have terminated...more

Hogan Lovells

Arbitration Bribery Corruption and Disputes - it's not as easy as ABCD

Hogan Lovells on

Foreign Corrupt Practices Act ("FCPA") - For energy, mining, and resources companies, the cost of corruption—and getting caught—is real. Less than two months ago, Odebrecht S.A. was ordered by a U.S. federal judge to pay a...more

Thomas Fox - Compliance Evangelist

Preparing for an Investigation

The Department of Justice’s (DOJ) Evaluation of Corporate Compliance Programs (Evaluation), under Prong 7 Confidential Reporting and Investigation asks the following: Properly Scoped Investigation by Qualified Personnel – How...more

Hogan Lovells

Why Healthcare and Life Sciences Companies Need to Step Up Their Compliance Efforts in Advance of a U.S. Government Investigation

Hogan Lovells on

In this hoganlovells.com interview, Hogan Lovells partner Gejaa Gobena discusses how the perception of compliance, remediation, and self-disclosure has evolved in the eyes of government prosecutors from how they factor at...more

Thomas Fox - Compliance Evangelist

John Fogarty Rocks-Nu Skin Informs Oversight

I recently saw John Fogerty in concert. For those you are not aware, he was a founding member and the driving force behind Creedence Clearwater Revival (CCR), one of the very top American groups from the 1960s and early...more

Skadden, Arps, Slate, Meagher & Flom LLP

Key Takeaways: Government Enforcement Investigations – Trends and Perspectives from the UK, US and China

On September 20, 2016, Skadden presented a seminar titled “Government Enforcement Investigations – Trends and Perspectives from the UK, US and China” in London. The UK Financial Conduct Authority (FCA) Director of Enforcement...more

Thomas Fox - Compliance Evangelist

Red Flags Squelch Corrupt PDVSA Deal

As the Petrobras corruption scandal seems to be going strong, we turn our attention to what may be the most corrupt of all the national energy companies, the Venezuelan state oil company Petroleos de Venezuela SA (PDVSA)....more

The Volkov Law Group

The Only Thing You Have to Fear . . . Is No Documentation

The Volkov Law Group on

Compliance is a profession that requires multi-tasking – another profound grasp of the obvious. But in the multi-tasking world, some principles and strategies are more important than others. My colleague and...more

Thomas Fox - Compliance Evangelist

What Can You Learn in the First Inning?

You might figure that the year I decide to jump back on the Houston Astros bandwagon, they go back in the tank. Last year they were one game away from the American League (AL) Championship. This year they have the third worst...more

K&L Gates LLP

DOJ Sharpens Focus on Corporate Compliance in Deciding Whether to Prosecute Companies

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One of the factors that the U.S. Department of Justice (DOJ) considers in deciding whether to bring charges against a corporation is the existence and effectiveness of the corporation’s pre-existing compliance program. On...more

The Volkov Law Group

US and China Expand Law Enforcement Cooperation

The Volkov Law Group on

Global anti-corruption efforts continue to increase. For global companies, this trend makes compliance even more critical. One of the most significant aspects of this trend is the US government’s cooperation with China....more

Sheppard Mullin Richter & Hampton LLP

They Grow Up So Fast: Alstom and the UK Bribery Act at Five Years

In April 2015, the UK Bribery Act (UKBA) celebrated its fifth birthday. In the same month, the Serious Fraud Office brought a third round of corruption charges under the UKBA in the Alstom case. Those allegations, brought...more

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