Episode 345 -- Raytheon Pays $950 Million to Resolve Fraud, FCPA, ITAR and False Claims Act Violations
Episode 333 -- The Boeing Proposed Plea Agreement
2 Gurus Talk Compliance: Episode 26 – The Compliance Week Wrap Up Edition
Episode 305 -- Deep Dive into SAP FCPA Settlement
Corruption, Crime, and Compliance - The Ericsson FCPA DPA Breach Settlement
Episode 258 -- Deep Dive into ABB FCPA Settlement
What DAG Lisa Monaco's Speech Means for Compliance Programs
Federal Monitorships and Making Them Work
FCPA Compliance Report - James Koukios on the Monaco Speech
Compliance Into The Weeds: DAG Announces Changes in Enforcement Priorities
Episode 160 -- A Deep Dive into the Herbalife FCPA Settlement
Everything Compliance-Episode 57-the Airbus edition
Episode 119 -- The Ericsson FCPA Settlement
Episode 117 -- FCPA Update: Samsung FCPA Settlement; Braskem Former CEO Indicted; Transport CEO Convicted after Trial
This Week in FCPA-Episode 96, 2018 - the Opening Day edition
FCPA Compliance and Ethics Report-Episode 134, Judge Rakoff, Judge Leon and their comments on DPAs, with the FCPA Professor
FCPA Compliance and Ethics Report Episode 129-Judge Rakoff, Judge Leon and Individual Prosecutions Under the FCPA
FCPA Compliance and Ethics Report-Episode 118-the Alstom FCPA Enforcement Action
FCPA Compliance and Ethics Report-Episode 31-the FCPA Year in Review, Corporate Enforcement Actions
FCPA Compliance and Ethics Report-Episode 30-Interview with the FCPA Professor-Part 2
On 24 April 2025, the Serious Fraud Office (SFO) issued new guidance signalling a notable shift in its approach to corporate criminal enforcement. For the first time, the SFO has stated that if a company self-reports...more
In October 2024, the Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) announced settlements with Raytheon Company, a division of multinational defense contractor RTX, over defective pricing and...more
The Department of Justice (DOJ) recently launched its Corporate Whistleblower Awards Pilot Program to tackle corporate misconduct under various laws. However, unlike the structured and familiar whistleblower frameworks of the...more
No Longer Just a Matter of Paying the Fine and Moving On. Corporate settlement agreements used to be straightforward—pay the penalty and move on. Now, these resolutions rival complex business transactions, including...more
Ericsson’s breach of its 2019 Deferred Prosecution Agreement reads like an internal investigation horror show. It is every investigator’s nightmare scenario – failure to discover evidence that was available to inform and...more
On January 17, 2023, Assistant Attorney General Kenneth A. Polite, Jr. (“AAG Polite”) announced several key revisions to the Department of Justice (“DOJ”) Criminal Division’s Corporate Enforcement Policy (the “CEP”) governing...more
When companies get into trouble, it’s common practice for the government to call on independent third parties to help clean up the mess. Companies under investigation by the Department of Justice (“DOJ”) often agree to...more
The Department of Justice (DOJ or Department), under the leadership of Attorney General Merrick Garland, has expressed that one of its top priorities in corporate criminal matters is “to prosecute the individuals who commit...more
On 17 July 2020, a three-year Deferred Prosecution Agreement (DPA) between the Serious Fraud Office (SFO) and G4S Care & Justice Services (UK) Ltd (G4S) was approved. This DPA is the second arising from fraudulent conduct in...more
Recently, three of Australia's four largest banks have self-reported breaches of anti-money laundering and counter-terrorism financing laws. Commonwealth Bank of Australia in 2018 admitted fault and agreed to pay a civil...more
On December 6, 2019, Telefonaktiebolaget LM Ericsson (Ericsson or the Company), resolved long-running investigations by the U.S. Department of Justice (DOJ) and the U.S. Securities and Exchange Commission (SEC) into the...more
As widely anticipated, French and U.K. regulators recently published guidance detailing their expectations for corporate cooperation in enforcement investigations. Both sets of guidance demonstrate further alignment of those...more
Recent Trends And Patterns In FCPA Enforcement - Although the DOJ and SEC brought a relatively low number of FCPA enforcement actions in the first half of 2019, an unusually large portion of those enforcement actions...more
Bob Dylan, Watch the River FlowI have to admit it – I still love to listen to Bob Dylan. With age, his lyrics resonate more and more. HERE is a nice version of Watch the River Flow in case you want to listen while reading...more
The national opioid epidemic is almost unprecedented in every conceivable way—its catastrophic death toll, its broad effect on a wide swath of this country’s population, its rapid escalation (which is alleged to have been...more
As reflected in recent remarks by Deputy Attorney General Rod Rosenstein, the United States Department of Justice (DOJ) is “reinforcing its relationship with good corporate citizens” by coordinating with, and considering, the...more
We had three major Foreign Corrupt Practices Act (FCPA) cases resolved in Q2 2018. They all reached different resolutions under the new FCPA Corporate Enforcement Policy and the new anti-piling on policy....more
On 19 March 2018, Singapore's Parliament ushered in a raft of criminal justice reforms, including the significant introduction of a deferred prosecution agreement ("DPA") regime. ...more
Today I conclude my two-part series on the recent Foreign Corrupt Practices Act (FCPA) enforcement action involving the Chilean chemicals and mining company Sociedad Química y Minera de Chile (SQM), which agreed to pay a...more
Enforcement activity under the Obama administration often made headlines for the eye-popping level of fines, with the Foreign Corrupt Practices Act (FCPA), Anti-Money Laundering (AML) regulations, and economic sanctions...more
Sometimes I get inspired when writing blog posts and sometimes I get on a roll. It is a bit of both this week and today, as previously this week, I have focused on Department of Justice (DOJ) pronouncements on their view of...more