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Corruption Due Diligence Corporate Misconduct

American Conference Institute (ACI)

The Big Picture: Anti-Corruption Enforcement and Integrity Program Developments in Brazil

The last several months brought forth major reforms to Brazil’s anti-corruption regulations and enforcement environment, including in the way that Brazilian companies are expected to enhance their compliance programs....more

Thomas Fox - Compliance Evangelist

The Bre-X Mining Scandal, Part 1: A Scandal for the Ages

Few corporate scandals are still as infamous or devastating as the Bre-X mining scandal. What began as a story of incredible wealth, fueled by the promise of one of the largest gold deposits ever discovered, unraveled into...more

Mintz

EnforceMintz — DOJ’s Efforts in 2023 to Incentivize Voluntary Self-Disclosure

Mintz on

2023 was a very active one for Department of Justice (DOJ or the “Department”) guidance, and that guidance had one clear theme: DOJ wants companies to voluntarily self-disclose their misconduct. To incentivize...more

Troutman Pepper Locke

The Stick and the Carrot: DOJ Continues to Eye Corporate Crimes, While Encouraging Prompt Self-Disclosures of Misconduct...

Troutman Pepper Locke on

On October 4, Deputy Attorney General (DAG) Lisa Monaco announced the Department of Justice’s (DOJ) new Safe Harbor Policy for voluntary self-disclosures made in connection with mergers and acquisitions (M&A). This policy is...more

Robinson & Cole LLP

DOJ Announces Extension of Voluntary Self-Disclosure Guidance for Misconduct Discovered Through M&A Due Diligence

Robinson & Cole LLP on

On October 4, 2023, the U.S. Department of Justice (DOJ) announced a uniform approach for the resolution of voluntary self-disclosure (VSD) of misconduct discovered during M&A due diligence. The Mergers & Acquisitions Safe...more

The Volkov Law Group

Lessons Learned from the KT Corp. SEC FCPA Settlement (Part III of III)

The Volkov Law Group on

Even though the size of the KT Corp. SEC enforcement action is relatively small, the underlying misconduct provides a number of important lessons learned. ...more

White & Case LLP

Does your compliance program address UK exposure?

White & Case LLP on

Tech companies of U.S. origin tend to have compliance programs focused on U.S. laws, including the Foreign Corrupt Practices Act (the "FCPA") and relevant tax and labor laws. The UK has enacted laws covering bribery and...more

Thomas Fox - Compliance Evangelist

Goldman Sachs, 1MDB and Initial Lessons Learned

This week I have been considering the new developments in the long-running 1Malaysia Development Berhad (1MDB) scandal. These developments include a guilty plea by a former Goldman Sachs Group Inc. (Goldman Sachs) banker in...more

Thomas Fox - Compliance Evangelist

Evolution of Best Practices – Part IV

In addition to enforcement actions, the Department of Justice’s (DOJs) 2016 FCPA Pilot Program, coupled with 2017’s Evaluation of Corporate Compliance Programs (Evaluation) and the FCPA Corporate Enforcement Policy, all...more

The Volkov Law Group

The Objective of Due Diligence: To Protect Your Culture

The Volkov Law Group on

There has been so much attention paid to due diligence. We have reams and reams of articles highlighting the importance of due diligence. In addition, numerous vendors of due diligence services and technologies fill the...more

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