Brazilian airplane manufacturer Embraer’s data has reportedly been uploaded on a dark web website hosted by ransomware group RansomExx (a/k/a Defray 777) after Embraer reportedly refused to pay a ransom following a ransomware...more
A rift in the space time continuum is similar to a tear in fabric, thereby creating a disconnect in this timeline. This is certainly what we saw in the district court’s opinion in EMPLOYEES RETIREMENT SYSTEM OF THE CITY OF...more
Coffee pod powerhouse Keurig Green Mountain is expanding its empire (and that of its parent JAB Holding Company) with the announcement of a $18.7 billion deal for the Dr Pepper Snapple Group. If approved by shareholders and...more
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
The Department of Justice (DOJ) and Securities and Exchange Commission (SEC) continued their stunning 2016 run of Foreign Corrupt Practices Act (FCPA) decisions with the announcement of the resolution of the Embraer SA...more
We begin the New Year with a three-part series on the FCPA: (1) A review of FCPA enforcement in 2016; (2) Trends from 2016 FCPA enforcement; and (3) Predictions for FCPA enforcement in 2017....more
Bribery and corruption remained a prominent fixture of media headlines throughout 2016, competing with the UK referendum on membership of the European Union, the Panama Papers leaks, and the continued activity of terrorist...more
There is no question that the Justice Department has raised compliance program expectations in a number of areas. Whatever you may think about the efficacy or fairness of the FCPA Pilot Program, the Justice Department has...more
Embraer SA, Brazil's flagship aerospace manufacturer and a worldwide competitor across various aviation markets, experienced first-hand the scope and reach of the Foreign Corrupt Practices Act (FCPA). Embraer agreed to pay...more
While reading the Embraer settlement documents, I read over the facts implicating a senior legal executive and his/her involvement in the Embraer bribery scheme. Truthfully, I had a slight gasp as I read about a fellow lawyer...more
The Embraer FCPA settlement action contains a number of important lessons learned and compliance reminders. In several significant respects, the Embraer case confirms in several areas why proactive compliance programs are...more
After years of investigation, disclosures, and press reports, the Embraer FCPA case finally came to a close. Hopefully, we will not see more of these long-term, seemingly endless investigations. The Justice Department and the...more
I conclude my exploration of the recently announced Department of Justice (DOJ) and Securities and Exchange Commission (SEC) Foreign Corrupt Practices Act (FCPA) enforcement action with the announcement of the resolution of...more
Today I continue my exploration of the recently announced Department of Justice (DOJ) and Securities and Exchange Commission (SEC) Foreign Corrupt Practices Act (FCPA) enforcement action with the announcement of the...more
In all honesty, if I were betting on my predictions, I would be broke. If I were setting the line on the Super Bowl, I am sure I would go bankrupt in paying off bets. With such confidence, you may want to just click to the...more