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Department of Justice (DOJ) Corruption Foreign Official

Dorsey & Whitney LLP

Should Your Company Shut Down Its Anti-Corruption Compliance Program and Start Paying Bribes? Here Are a Few Reasons to Think...

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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

BakerHostetler

Congress Expands DOJ’s Power to Prosecute Corruption with the Foreign Extortion Prevention Act

BakerHostetler on

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 Volkov Law Group

DOJ’s Latest Opinion Release Underscores Absence of Corrupt Intent and Lack of Business Purpose

The Volkov Law Group on

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 Volkov Law Group

Lessons Learned from the Albemarle FCPA Enforcement Action: Mind Your Third Parties (Part III of III)

The Volkov Law Group on

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

Thomas Fox - Compliance Evangelist

Sargeant Marine – The Individual Guilty Pleas

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

BakerHostetler

DOJ Releases First FCPA Advisory Opinion in Six Years

BakerHostetler on

On August 14, 2020, the Department of Justice (the “DOJ”) issued its first Foreign Corrupt Practices Act (the “FCPA”) advisory opinion in almost six years....more

The Volkov Law Group

DOJ Secures Guilty Plea and Charges A Second Former PDVSA Official with Money Laundering

The Volkov Law Group on

The Justice Department continues to pursue criminal cases against Venezuelan officials at Petróleos de Venezuela S.A. (PDVSA) in an attempt to strangle President Nicolas Maduro.  DOJ has been pursuing a three-pronged strategy...more

The Volkov Law Group

Three Individuals Charged with Fraud and FCPA Violations in International Adoption Scheme

The Volkov Law Group on

FCPA cases can arise in un usual situations.  DOJ has focused two separate prosecutions on bribery and fraud involving adoptions from Uganda and Poland.  At the heart, the defendants bribed Ugandan and Polish authorities to...more

The Volkov Law Group

Revised FCPA Guidance: Legal Issues and Clarifications (Part IV of V)

The Volkov Law Group on

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

The Volkov Law Group

Revised FCPA Guidance: New Case Updates (Part II of V)

The Volkov Law Group on

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

WilmerHale

$1 Billion Ericsson Resolution, Three Jury Verdicts Cap Off Busy Fourth Quarter for US FCPA Enforcement

WilmerHale on

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

Dorsey & Whitney LLP

Former Alstom Executive Convicted of Foreign Corrupt Practices Act Charges on Agency Theory

Dorsey & Whitney LLP on

Lawrence Hoskins, a British citizen and former employee of French conglomerate Alstom SA, has been found guilty by a federal jury in Connecticut of 11 of 12 criminal charges, including six counts of violating the United...more

McDermott Will & Emery

Second Circuit Declines to Limit FCPA's Scope

McDermott Will & Emery on

The Second Circuit’s decision in United States v. Ng Lap Seng is a win for the government, because it reinforces the broad reach and scope of the Justice Department’s enforcement of the FCPA. When adopting and implementing an...more

Ballard Spahr LLP

Two Former Venezuelan Officials and Energy Executives Indicted as DOJ Continues to Use Money Laundering Charges to Combat Foreign...

Ballard Spahr LLP on

Last week, a grand jury in the Southern District of Florida indicted two former Venezuelan officials, charging them with seven counts of money laundering and one count of money-laundering conspiracy. The charges relate to...more

The Volkov Law Group

Lessons Learned and Trends from MTS FCPA Enforcement Action and Criminal Indictment of Karimova and Akhmedov (Part III of III)

The Volkov Law Group on

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 Volkov Law Group

Anatomy of MTS, Karimova and Akhmedov Bribery Scheme in Uzbekistan (Part II of III)

The Volkov Law Group on

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

Thomas Fox - Compliance Evangelist

Foreign Officials as Agents – Opinion Release 10-03

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

Seyfarth Shaw LLP

Batter Up: The FCPA Takes A Swing At Major League Baseball

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Seyfarth Synopsis: Among the latest news reports in the cross-border public corruption space that has legally-minded sports fans talking is that a federal grand jury is investigating Major League Baseball’s international...more

Thomas Fox - Compliance Evangelist

The Credit Suisse FCPA Enforcement Action: Part I – Background

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

Thomas Fox - Compliance Evangelist

Transparency, FCPA Enforcement and the Rule of Law

In a win for transparency, the rule of law and the international fight against bribery and corruption, the Department of Justice (DOJ) secured a victory in all three categories with the sentencing of Egbert Yvan Ferdinand...more

BCLP

Anti-Corruption Enforcement: Analyzing the Enforcement Approaches of the US, the UK and France

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Anti-Corruption enforcement is a top priority in France, the UK, and the US. Each of these countries has armed its enforcers with the enforcement tools necessary to investigate and prosecute corporations and individuals. Join...more

Jones Day

Anti-Corruption Regulation Survey of 41 Countries 2017–2018

Jones Day on

Welcome to the 2017-2018 edition of the Jones Day Anti-Corruption Regulation Survey. In 2017 and 2018 to date, there has continued to be an increasing awareness among multinational companies of the significance of...more

BakerHostetler

Foreign Corrupt Practices Act 2017 Year-End Update

BakerHostetler on

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 Volkov Law Group

Justice Department Closes Out 2017 with 2 FCPA Actions: Keppel Offshore and Marine and Embraer Individual

The Volkov Law Group on

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

K&L Gates LLP

Takeaways from the 34th International Conference on the Foreign Corrupt Practices Act

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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

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