Podcast - “I Lied Like a Dog!”
Sittenfeld v. United States – Campaign Contributions as Crimes?
Podcast - Persistence and Determination
Episode 377 -- Refocusing Due Diligence on Cartels and TCOs
10 For 10: Top Compliance Stories For the Week Ending, July 12, 2025
RICO Section 1962(b): Acquisition or Maintenance of Control Over Legitimate Enterprises — RICO Report Podcast
Podcast - The Seeds of Corruption
False Claims Act Insights - Bitter Pills: DOJ Targets Pharmacies for FCA Enforcement
Episode 374 -- Justice Department Resumes FCPA Enforcement with New, Focused Guidance
Daily Compliance News: June 16, 2025, The Golden Share Edition
The JustPod: Defending the "Evil Genius:" A Conversation with Leonard Ambrose
The Presumption of Innocence Podcast: Episode 62 - The Tragic Toll of Conspiracy Theories: The Seth Rich Story
SBR-Author’s Podcast: The Unseen Life of an Undercover Agent: A Conversation with Charlie Spillers
Podcast - "Ready for Trial?"
Podcast - The Law as a Force for Change
The JustPod: A Discussion with Defense Counsel Rocco Cipparone and Angie Levy on January 6 Prosecutions
False Claims Act Insights - Trump DOJ Sharpens Its Focus on Healthcare Fraud
The JustPod: A murder-for-hire allegation, public corruption trial, and notable acquittal
Podcast - Every Case Is a New World
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
On June 9, U.S. Deputy Attorney General Todd Blanche issued a memorandum entitled “Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act (FCPA),” which establishes guidelines to ensure that FCPA...more
On 12 February 2025, the UK Supreme Court handed down its decision in El-Khouri v Government of the United States of America (El-Khouri), declining to extradite Joseph El-Khouri to the US. The ruling marks a pivotal moment in...more
In 2017, when President Trump first took office, big changes were expected in FCPA enforcement. Much of this reflected President Trump’s expressed misgivings on the substance of the FCPA. He was not a big fan of the law and...more
Ericsson, a multinational telecommunications company, based in Sweden, settled its breach of its 2019 Deferred Prosecution Agreement, agreed to enter a guilty plea and pay a $206 million penalty. In 2019, Ericsson entered...more
The following summarizes our team’s monitoring of key developments in anti-corruption enforcement during 2022 and what that may mean going forward in this new year:.....more
Just as the Department of Justice (DOJ) has long focused on financial incentives in a best practices compliance program, it has equally focused on punishing those officers and employees who fail to do business ethically and...more
As expected when a new administration takes office, 2021 saw a surge in white-collar enforcement activity. There was a 12% increase in white-collar prosecutions during US President Joe Biden’s first year in office, and that...more
A. Basic Overview of Statute - The Foreign Corrupt Practices Act of 1977, as amended, 15 U.S.C. §§ 78dd-1, et seq. (FCPA), makes it unlawful for U.S. persons and entities and others who act within the jurisdiction of the...more
The Biden administration took office in January 2021, announcing aggressive and sweeping anticorruption initiatives to tackle corruption around the world, labeling corruption a national security priority, and signaling a...more
In September 2020, Patrick Mincey, Zachary Bolitho and I presented on the changes and trends we expected to see in SEC and DOJ enforcement of white-collar cases. We cautioned our clients that the government was going to...more
The SEC’s FCPA settlement with WPP for over $19.2 million provides a variety of bribery schemes in several high-risk venues. The schemes are instructive because they remind anti-corruption compliance professionals of the...more
The Justice Department and the Securities Exchange Commission are back in business. The first corporate FCPA enforcement action in 2021 came after a six-month hiatus in 2021. While many commentators sought to read the...more
The Biden administration is widely expected to be tougher on corporate wrongdoing than its predecessor. Although there have not yet been significant changes to existing policies, key nominations to date and early enforcement...more
The year 2020 witnessed a record level of $2.78 billion in corporate fines and penalties from enforcement of the Foreign Corrupt Practices Act (FCPA) by the U.S. Department of Justice (DOJ) and the U.S. Securities and...more
In 2020, the biggest Foreign Corrupt Practices Act (“FCPA”) headline was the record-shattering global anticorruption enforcement fines and penalties collected by foreign regulators in actions involving a coordinated FCPA...more
J&F Investmentos SA (“J&F), a Brazilian private investment company, plead guilty to FCPA bribery violations in federal court in Brooklyn, New York. As part of the plea agreement, J&F agreed to pay a fine of $256 million and...more
For the first time in six years, the Department of Justice (DOJ) has released an Opinion Release, denominated 20-01. At first blush it appears to be a straight-forward recitation of the equivalent of black letter law in the...more
IN THIS ISSUE • Anticorruption Developments • Export Control Sanctions and Customs Enforcement • Export Control and Sanctions Developments • Global Investigations Resources • Writing and Speaking Engagements ...more
While DOJ had its biggest year in FCPA enforcement, OFAC quietly had a record year in enforcement. OFAC collected approximately $1.28 billion (yes, with a B) in 26 separate enforcement actions. That is quite an increase...more
It is time to break out the crystal ball for FCPA 2020 Predictions. In preparing for this, I always rely on my past admiration of Carnac the Magnificent....more
In a record year, there are bound to be numerous interesting enforcement actions and principles. I picked out a few to highlight....more
Happy New Year!! In the FCPA arena, 2019 was a record year – in enforcement and compliance. Many continuing trends are becoming more than trends – meaning they are turning into established practices....more