News & Analysis as of

Department of Justice (DOJ) Third-Party Risk Enforcement Actions

Ankura

The Extended Network: Managing Third Parties' Bribery Risks

Ankura on

Approximately 90% of U.S. Foreign Corrupt Practices Act (FCPA) enforcement cases from its inception in 1978 have involved third-party intermediaries engaging in bribery schemes. The reduced level of control or oversight...more

American Conference Institute (ACI)

[Event] Mexico Summit on Anti-Corruption & Compliance Programs - March 12th - 13th, Polanco, CDMX, Mexico

Connect with the leading Anti-Corruption experts and discuss the latest compliance strategies at ACI’s Mexico Summit on Anti-Corruption & Compliance Programs. As Mexico’s longest running, premier anti-corruption and...more

The Volkov Law Group

FCPA 2024 Enforcement — Bribery Schemes and Compliance Reminders (Part II of III)

The Volkov Law Group on

Criminals can be creative — that is a true statement but essentially FCPA criminals have to embrace a variety of well-established techniques to accomplish a straight-forward goal — steal money from the company to funnel...more

Society of Corporate Compliance and Ethics...

[Virtual Event] Government Contracting Compliance & Ethics Conference - February 27th, 8:00 am - 5:00 pm CT

Stay on top of the complexities of government contracting - Few industries are as heavily regulated or complex as government contracting. If your organization performs government-contracted services, or if you are charged...more

Thomas Fox - Compliance Evangelist

Changing Sales Models

Over the past 12 months or so there have been a series of Foreign Corrupt Practices Act (FCPA) enforcement actions where the respondents have changed and/or modified their sales models to get away from external third parties...more

Nutter McClennen & Fish LLP

Nutter Bank Report: February 2024

The U.S. Department of Justice (DOJ) and state authorities have agreed to a consent order with a large national bank to resolve allegations that the bank engaged in a pattern or practice of lending discrimination by affecting...more

American Conference Institute (ACI)

[Event] 17th Forum on the Foreign Corrupt Practices Act - January 24th - 25th, Houston, TX

As the most anticipated gathering for the community in Texas and the region, don’t miss out on re-connecting with your peers and more! With the continued focus on FCPA compliance and the anticipated rise in enforcement,...more

American Conference Institute (ACI)

[Event] 11th Annual Advanced Forum on False Claims and Qui Tam Enforcement - January 23rd - 24th, New York, NY

Hosted by American Conference Institute, the 11th Annual Advanced Forum on False Claims and Qui Tam Enforcement returns for another exciting year for lively discussions on FCA enforcement including the ramifications of two...more

American Conference Institute (ACI)

[Event] 40th International Conference on the FCPA - November 28th - 30th, National Harbor, MD

Hosted by American Conference Institute, the 40th International Conference on the FCPA returns for another exciting year with curated programming that shines a global spotlight on anti-corruption compliance challenges,...more

American Conference Institute (ACI)

[Event] Summit on Anti-Corruption & Compliance Programs - March 22nd - 23rd, Mexico City, Mexico

Hosted by American Conference Institute, the Mexico Summit on Anti-Corruption & Compliance Programs returns for another exciting year with curated programming that shines a global spotlight on anti-corruption compliance...more

ArentFox Schiff

Managing Third-Party Risk: Recent FCPA Action Reflects Government’s Continued Focus on Intermediaries

ArentFox Schiff on

Amec Foster Wheeler Energy Limited (the Company), a subsidiary of John Wood Group plc (Wood), a United Kingdom-based global engineering company, agreed to pay more than $41 million in penalties and disgorgement for alleged...more

WilmerHale

OFAC Enforcement Actions Highlight Risks to Software Providers & MSBs

WilmerHale on

On April 29, 2021, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced two settlements of potential civil liability with two companies over their apparent violations of its regulations. The...more

American Conference Institute (ACI)

[Virtual Event] 37th International Conference on the FCPA - December 2nd - 3rd, 9:00 am - 4:30 pm EST

The Annual Gathering for the Global Anti-Corruption Community - Exclusive Interview with President of Microsoft at FCPA DC - The world has reached an inflection point in which digital technology is being used as both a...more

The Volkov Law Group

2019 OFAC Sanctions Enforcement Review (Part I of II)

The Volkov Law Group on

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

Thomas Fox - Compliance Evangelist

Billion Dollar Baby: Ericsson FCPA Enforcement Action – Part 5: Lessons Learned for the Compliance Professional

Last week the Justice Department (DOJ) announced a resolution of the long standing Foreign Corrupt Practices Act (FCPA) enforcement action involving Telefonaktiebolaget LM Ericsson (Ericsson), a multinational networking and...more

Thomas Fox - Compliance Evangelist

Billion Dollar Baby: Ericsson FCPA Enforcement Action - Part 4: The Double Whammy in Penalties

Last week the Justice Department (DOJ) announced a resolution of the long standing Foreign Corrupt Practices Act (FCPA) enforcement action involving Telefonaktiebolaget LM Ericsson (Ericsson), a multinational networking and...more

Thomas Fox - Compliance Evangelist

Billion Dollar Baby: Ericsson FCPA Enforcement Action – Part 3: Internal Control Failures

Last week the Justice Department (DOJ) announced a resolution of the long standing Foreign Corrupt Practices Act (FCPA) enforcement action involving Telefonaktiebolaget LM Ericsson (Ericsson), a multinational networking and...more

The Volkov Law Group

Ericsson’s Pervasive Bribery Conduct: The Toxic Mix of Senior Executive Involvement and Third Party Corruption (Part II of II)

The Volkov Law Group on

Ericsson’s FCPA settlement is in the books (not the books and records).  But it casts a significant shadow across the FCPA landscape.  A pervasive and systemic culture of bribery is defined to reflect senior executive...more

The Volkov Law Group

Lessons Learned from the Walmart FCPA Enforcement Action (Part III of III)

The Volkov Law Group on

This is a tough posting – frankly, there are so many lessons learned from the Walmart case that they could fill a book, or an e-book at least.  I will focus on some of the big issues....more

Thomas Fox - Compliance Evangelist

Fresenius FCPA Enforcement Action: Part VI – FCPA Enforcement Going Forward

We are at the end of my exploration of the long-awaited Fresenius Medical Care AG & Co. KGaA (FMC) Foreign Corrupt Practices Act (FCPA) enforcement action. ...more

Thomas Fox - Compliance Evangelist

Fresenius FCPA Enforcement Action: Part III – The NPA, Fines and Monitor

I continue my multipart (not quite sure how long it will go) exploration of last week’s announcement of the Fresenius Medical Care AG & Co. KGaA (FMC) Foreign Corrupt Practices Act (FCPA) enforcement action. It involved...more

Thomas Fox - Compliance Evangelist

Fresenius FCPA Enforcement Action: Part II –  The Bribery Schemes

Last week, the long-awaited Fresenius Medical Care AG & Co. KGaA (FMC) Foreign Corrupt Practices Act (FCPA) enforcement action was announced. It involved massive multi-year and multi bribery schemes by the company in multiple...more

The Volkov Law Group

Lessons Learned from Fresenius Medical FCPA Settlement (Part III of III)

The Volkov Law Group on

Fresenius Medical’s FCPA settlement for $231 million demonstrates again the continuing vitality surrounding the FCPA Corporate Enforcement Policy – which provides a carefully constructed framework for encouraging voluntary...more

The Volkov Law Group

Lessons Learned from the Cognizant FCPA Resolution (Part IV of IV)

The Volkov Law Group on

The Cognizant FCPA enforcement action will go down as a problematic resolution for the policy reasons mentioned in my last post. Putting those concerns aside, there are some important lessons learned and observations that...more

The Volkov Law Group

FCPA Recidivists: Zimmer Biomet (Part I of II)

The Volkov Law Group on

The drug and medical device industries have been taking it on the FCPA chin for years. The risk factors in the international marketplace are significant – healthcare professionals are normally government employees; government...more

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