Hill Country Authors – Exploring the Challenges of a Green Transition with Tom Ortiz
Daily Compliance News: August 5, 2025, The Staying Focused Edition
Daily Compliance News: August 1, 2025, The All AI Edition
Daily Compliance News: July 31, 2025 the Forgotten Generation Edition
Just Press "Play"
Everything Compliance: Shout Outs and Rants: Episode 158, No To Ukraine Corruption
Daily Compliance News: July 29, 2025 the Is CEO Conduct Ever Personal Edition
Daily Compliance News: July 25, 2025, The New Sheriff in Town Edition
Daily Compliance News: July 23, 2025 the Pardon in the Wind? Edition
Daily Compliance News: July 22, 2025, The I-9 Hell Edition
10 For 10: Top Compliance Stories For the Week Ending July 19, 2025
Sittenfeld v. United States – Campaign Contributions as Crimes?
Podcast - Walking Tall
Podcast - The Seeds of Corruption
The Dark Patterns Behind Corporate Scandals
10 For 10: Top Compliance Stories For the Week Ending June 21, 2025
Daily Compliance News: June 19, 2025, The Corruption in Spain Edition
Daily Compliance News: June 9, 2025, The Repugnant Edition
10 For 10: Top Compliance Stories For the Week Ending June 7, 2025
On February 10, 2025, President Trump issued a new Executive Order (“EO”) titled “Pausing Foreign Corrupt Practice Act Enforcement to Further American Economic and National Security.” This EO comes on the tail of Attorney...more
Australia has a zero-tolerance approach to corruption, and this policy knows no border or nationality. Bribery or attempts to bribe foreign public officials are considered severe crimes, as mentioned in division 70 of the...more
On December 14, 2023, Congress passed the Foreign Extortion Prevention Act (“FEPA”) in an effort to address certain deficiencies inherent in the current iteration of the Foreign Corrupt Practices Act (“FCPA”), as part of the...more
Adding to federal prosecutors’ tool kit in fighting global corruption, on December 14, 2023, Congress passed with bipartisan support, the Foreign Extortion Prevention Act (FEPA). As part of the National Defense Authorization...more
The Justice Department has had a slow year in FCPA enforcement (another profound grasp of the obvious). The reasons for this may be a question of timing elements in the pipeline of cases....more
The Albemarle FCPA enforcement action was announced at a good time. This year has been a slow year for DOJ’s FCPA enforcement program, although there are several months before the end of the year. The SEC, on the other hand,...more
On October 1, 2020, the new Instruction on the Investigation and Prosecution of Foreign Corruption for the Dutch Public Prosecution Service ("DPPS") entered into force, indicating certain factors that play a role in...more
Last week, I began a multi-part exploration of one world’s largest anti-corruption enforcement actions, the J&F Investimentos SA (J&F) matter. It involved huge fines and penalties in both Brazil and the United States. Of...more
We rarely have seen a single Foreign Corrupt Practices Act (FCPA) enforcement action generate so many individual criminal pleas. The Sargeant Marine Inc. (Sargeant Marine) case is an exception. To date, there have been six...more
FCPA practitioners often debate whether the FCPA is “clear” or “ambiguous.” Like all important issues in life (assuming this is important), the answer really depends on the specific language. Congress’ ability to write...more
Over the last eight years, FCPA litigation has increased. Companies are still avoiding the risks of litigation and losing to the Justice Department and the SEC. Individuals, on the other hand, have clear incentives to...more
Enforcement authorities have attempted in recent years to increase their war on bribery and corruption. We therefore have seen a number of elected officials investigated for such offenses, viewed as some of the most serious...more
On December 6, 2019, the Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) agreed to resolve allegations that multinational telecommunications company Telefonaktiebolaget LM Ericsson (Ericsson or...more
Barclays joined the club of global financial institutions settling FCPA violations for hiring of relatives of foreign officials in Asia. Barclays agreed to disgorge $3.8 million and paid prejudgment interest of nearly $1...more
The MTS FCPA enforcement action stands as one of several significant prosecutions in FCPA history. The breadth and depth of MTS’ corruption scheme stands as another example of systemic bribery cultures. The details of the...more
The MTS bribery scandal in Uzbekistan represents the culmination of several significant FCPA violations involving VimpelCom, Telia Sonera, MTS, and Gulnara Karimova, the notoriously corrupt daughter of the former Uzbek...more
Can you hire a foreign official as your agent? Is a foreign official always a foreign official for the purposes of the Foreign Corrupt Practices Act (FCPA)? Can a person be a foreign official yet not under a contract for...more
Companies have definitely matured in the development and implementation of their ethics and compliance programs. Whether the pace has been rapid enough or is too slow, that is a debatable issue. A good litmus test for a...more
This blog post continues my multi-part exploration of the Petróleo Brasileiro S.A. – Petrobras (Petrobras) Foreign Corrupt Practices Act (FCPA) enforcement action. Today we take up some of the more prominent bribery schemes...more
When you read through the United Technologies SEC FCPA enforcement action, you cannot help but shake your head – the level of abuse and participation by senior managers in the UT companies – Pratt & Whitney and Otis Elevator...more
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
2017 marked the fortieth anniversary of the Foreign Corrupt Practices Act (FCPA), and showed continued robust enforcement against both individuals and companies by the U.S. Department of Justice (DOJ) and the U.S. Securities...more
The Department of Justice finished 2017 with two significant FCPA enforcement actions, and fittingly, one was a corporate settlement and another was an individual criminal guilty plea. The Justice Department’s final FCPA...more
At the 34th International Conference on the Foreign Corrupt Practices Act held last week in Washington, D.C., industry executives, members of the defense bar, and regulators examined developments in the enforcement of the...more
The single most frequently asked question by our international clients over the past several months is whether there will be changes in white collar prosecution priorities under the new administration, specifically with...more