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Department of Justice (DOJ) FCPA Guidance Bribery

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for July 2025

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

Thomas Fox - Compliance Evangelist

Deere’s FCPA Case: Lessons on Gifts, Travel and Entertainment

We recently had a Foreign Corrupt Practices Act (FCPA) enforcement action that reminded me that everything old is new again in anti-corruption compliance. The Securities and Exchange Commission (SEC) FCPA enforcement action...more

Thomas Fox - Compliance Evangelist

The Trafigura FCPA Enforcement Action – Part 1 – Introduction

In March 2024, the Department of Justice (DOJ) announced the resolution of a Foreign Corrupt Practices Act (FCPA) enforcement action involving the Swiss trading firm G Trafigura Beheer B.V. (Trafigura), an international...more

The Volkov Law Group

Top Compliance Reminders from 2023 FCPA Enforcement

The Volkov Law Group on

While 2023 was a relatively slow year in FCPA enforcement, the DOJ and SEC settlements announced throughout the year set out a list of important ethics and compliance reminders. While these may seem obvious to everyone, I...more

Thomas Fox - Compliance Evangelist

What 2023 Brought to Compliance

2023 was a very significant year for every compliance practitioner and compliance program. While there was a paucity of corporate enforcement actions under the Foreign Corrupt Practices Act (FCPA), there were significant...more

Littler

Proper Planning and Swift Action Can Help Employers Avoid Foreign Corrupt Practices Act Prosecution

Littler on

While the Department of Justice (DOJ) has initiated at least two new Foreign Corrupt Practices Act (FCPA) enforcement actions against U.S. companies, it has also announced several decisions not to prosecute—most recently...more

The Volkov Law Group

Lessons Learned from the Tysers Insurance Brokers and H.W. Wood Limited FCPA Settlements (Part III of III)

The Volkov Law Group on

The Tysers and Wood FCPA settlements reflect something old and something new in the FCPA enforcement world. On the old side, at the core of the FCPA violations was the critical role played by the intermediary company....more

Morgan Lewis

Anti-Bribery And Corruption Survey Report

Morgan Lewis on

Survey: Tech gaps, third parties pose biggest ABAC threats - Compliance professionals surveyed regarding their anti-bribery and corruption efforts (ABAC) indicated resource support deficiencies in areas including staffing...more

The Volkov Law Group

Corsa Coal Earns Declination and Agreed to Disgorge $1.2 Million

The Volkov Law Group on

The Justice Department has been pushing its voluntary self-disclosure program and changes to its Corporate Enforcement Policy, in an attempt to increase FCPA enforcement cooperation.  The Golden Ring for every company facing...more

The Volkov Law Group

The Importance of Accounting and Internal Controls (Part I of II)

The Volkov Law Group on

Here are some basic propositions that surround FCPA compliance. It is often underplayed that the FCPA contains more than just a bribery prohibition – the FCPA contains broad provisions, requiring accurate books and records...more

The Volkov Law Group

What Can We Expect in Future FCPA Enforcement Actions?

The Volkov Law Group on

In the FCPA and white collar defense community, we have seen buckets and buckets of ink spilled on the coming wave of aggressive enforcement.  Justice Department officials have made so many statements about the “new” approach...more

The Volkov Law Group

DOJ FCPA Opinion Letter Draws Lines Regarding “Corrupt Intent” and the “Business Purpose” Test

The Volkov Law Group on

Even with the absence of any major DOJ FCPA enforcement actions, DOJ issued an interesting FCPA Opinion Letter last week addressing application of the FCPA in circumstances where organizations face imminent serious bodily...more

Foodman CPAs & Advisors

Mejores prácticas bajo la Guía de Recursos Actualizada de la FCPA

El 3 de Julio del 2020, el Departamento de Justicia de los Estados Unidos (“DOJ”) lanzó “Una guía de Recursos para la Ley de Prácticas Corruptas en el Extranjero de los Estados Unidos, segunda edición“....more

Troutman Pepper Locke

Three Takeaways from the Updated DOJ and SEC FCPA Resource Guide

Troutman Pepper Locke on

On July 3, 2020, the U.S. Department of Justice and the Securities and Exchange Commission issued a Second Edition of the Resource Guide to the U.S. Foreign Corrupt Practices Act (the Guide), representing the Guide’s first...more

Orrick, Herrington & Sutcliffe LLP

Takeaways from the Second Edition of the DOJ and SEC's FCPA Resource Guide (July 2020)

On July 3, the Criminal Division of the U.S. Department of Justice (“DOJ”), and the Enforcement Division of the U.S. Securities and Exchange Commission (“SEC”) released an updated joint Resource Guide to the U.S. Foreign...more

Cadwalader, Wickersham & Taft LLP

DOJ and SEC Update FCPA Resource Guide for 2020 – What’s New and What Does It Mean?

On July 3, 2020, the Department of Justice (“DOJ”) and Securities and Exchange Commission (“SEC”) updated their 2012 joint guidance on the Foreign Corrupt Practices Act (“FCPA”) in the SEC and DOJ’s FCPA Resource Guide...more

The Volkov Law Group

Revised FCPA Guidance: Updated DOJ Policies (Part III of V)

The Volkov Law Group on

The Justice Department has continued at a steady rate to tweak relevant policies applicable to FCPA enforcement.  The Revised FCPA Guidance has incorporated these policies....more

Foley Hoag LLP

DOJ and SEC Release Second Edition of FCPA Resource Guide

Foley Hoag LLP on

On July 3, 2020, the Department of Justice (“DOJ”) and the Securities and Exchange Commission (“SEC”) released the Second Edition of their Resource Guide to the U.S. Foreign Corrupt Practices Act (the “Resource Guide”). As...more

The Volkov Law Group

DOJ Tweaks FCPA Corporate Enforcement Policy

The Volkov Law Group on

The Department of Justice recently announced updates to its Foreign Corrupt Practices Act Corporate Enforcement Policy. While the changes were relatively minor, the modifications underscored important principles surrounding...more

Foodman CPAs & Advisors

Did you know that there is FCPA Individual Compliance Responsibility?

Foodman CPAs & Advisors on

The Foreign Corrupt Practices Act (FCPA) prohibits payment of bribes to foreign officials to assist with obtaining or retaining business.  It also requires companies whose securities are listed in the US to make and keep...more

Troutman Pepper Locke

Enhanced Anti-Corruption Scrutiny in Construction Industry

Troutman Pepper Locke on

Bribery and corruption have long plagued the construction industry, particularly in emerging markets in Latin America, Eastern Europe, the Middle East and Asia-Pacific. ...more

Thomas Fox - Compliance Evangelist

The Updated Evaluation of Corporate Compliance Programs – Guidance Document: Part 7 – M&A

We conclude our exploration of the recently released Evaluation of Corporate Compliance Programs – Guidance Document(2019 Guidance), which was announced(ECI speech) by Assistant Attorney General Brian Benczkowski at the...more

Thomas Fox - Compliance Evangelist

The Awards Season and DOJ Look at International Sporting Events

One might have hoped that after the Fédération Internationale de Football Association (FIFA) scandals from 2015, both before and beyond, the world’s most popular sport might have worked to clean up its act more diligently....more

The Volkov Law Group

Calculating the New Balance Between Disclosure and Non-Disclosure of Potential FCPA Violations

The Volkov Law Group on

The Justice Department’s new FCPA Corporate Enforcement Policy has altered the balance between disclosure and non-disclosure of FCPA violations. How is that for a profound grasp of the obvious?...more

The Volkov Law Group

Pushing Ethics and Compliance Programs in the New FCPA Corporate Enforcement Policy

The Volkov Law Group on

The Justice Department’s aggressive enforcement program, particularly in the FCPA arena, has been the primary impetus to the growth and empowerment of the corporate compliance function. The Justice Department and SEC’s FCPA...more

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