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Enforcement Actions Corruption Chief Compliance Officers

American Conference Institute (ACI)

SFO’s Enforcement Strategy Focuses on Corporate Liability

The U.K. Serious Fraud Office has a lot going for it right now: a director hellbent on tackling complex fraud, bribery, and corruption, an enhanced budget, new partnerships to tackle international bribery and corruption...more

Thomas Fox - Compliance Evangelist

Using Data Analytics to Create an Effective Compliance Program - Part 1

I recently had the opportunity to visit with Vince Walden for the inaugural episode of the newest podcast on the Compliance Podcast Network, Data Driven Compliance. Walden is a compliance professional with 15 years of...more

Thomas Fox - Compliance Evangelist

Profit Sharing as Bribery: The Honeywell FCPA Enforcement Action: Part 1 – Introduction

To close out 2022 in Foreign Corrupt Practices Act (FCPA) enforcement actions, the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) both announced settlements of FCPA enforcement actions with Honeywell...more

Thomas Fox - Compliance Evangelist

What 2022 Brought to Compliance

2022 was a very significant year for every compliance practitioner and compliance program. While there was a paucity of corporate FCPA enforcement actions, there were three enforcement actions were significant with multiple...more

Brownstein Hyatt Farber Schreck

DOJ Introduces a Mix of ‘Carrots and Sticks’ to Combat Corporate Crime

The Department of Justice is sending a clear message to companies when it comes to corporate crime: invest in strong compliance structures and culture and come forward quickly with information about misconduct—or suffer the...more

The Volkov Law Group

DOJ CCO Certification Requirements and DOJ Compliance Mandates (Part II of III)

The Volkov Law Group on

The new DOJ Certification requirements certainly raise a number of new issues and risks for senior management and chief compliance officers.  In Part I of this series, I outlined the specific language and the Plea Agreement...more

Thomas Fox - Compliance Evangelist

2021 – The Year in FCPA Enforcement

There was a paucity of Foreign Corrupt Practices Act (FCPA) enforcement actions in 2021. However, the few enforcement actions announced did provide significant lessons for every compliance professional....more

Thomas Fox - Compliance Evangelist

What 2021 Brought to Compliance

2021 was a very significant year for every compliance practitioner and compliance program. While there was a paucity of corporate FCPA enforcement actions, the three enforcement actions were significant with multiple lessons...more

The Volkov Law Group

HR and CCOs Watch Out!! — The Antitrust Division Doubles Down on Labor Market Criminal Cartel Activity

The Volkov Law Group on

The Justice Department’s Antitrust Division has targeted collusion in labor markets for criminal prosecution.  This was not unexpected.  Indeed, the Antitrust Division gave plenty of warning to companies that criminal...more

Thomas Fox - Compliance Evangelist

Foster Wheeler Settles Corruption Allegations – Silk Shirts and Corruption

I am continuing my review of the Amec Foster Wheeler (Foster Wheeler) international corruption enforcement action. Today, I want to focus on the underlying facts of the corruption. These facts are laid out in the Department...more

Thomas Fox - Compliance Evangelist

The Herbalife FCPA Enforcement Action: Part 4 – Final Thoughts

We are the end of my multi-part exploration of the Herbalife Nutrition Ltd (Herbalife) Foreign Corrupt Practices Act (FCPA) enforcement action with both the Department of Justice (DOJ) and Securities and Exchange Commission...more

Thomas Fox - Compliance Evangelist

The Significance of Opinion Release 20-01

For the first time in six years, the Department of Justice (DOJ) has released an Opinion Release, denominated 20-01. At first blush it appears to be a straight-forward recitation of the equivalent of black letter law in the...more

Thomas Fox - Compliance Evangelist

Top SEC Enforcement Actions from 2019

Yesterday, I considered five Department of Justice (DOJ) Foreign Corrupt Practices Act (FCPA) enforcement actions. Today, I want to look at key FCPA enforcement actions by the Securities and Exchange Commission (SEC)....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

Thomas Fox - Compliance Evangelist

MTS FCPA Settlement and Karimova Indictment: Lessons for Compliance Practitioners

This white paper will examine the background facts of the Mobile TeleSystems PJSC (MTS) FCPA case, provide a detailed review of the bribery schemes involved, the compliance failures of MTS and its actions during the...more

WilmerHale

Foreign Corrupt Practices Act Alert: Global Anti-Bribery Year-in-Review: 2018 Developments and Predictions for 2019

WilmerHale on

Despite predictions of a slow-down in enforcement under the Trump administration—and indications that enforcement in some areas has decreased in the past year1—2018 was yet again an active year for FCPA enforcement. The year...more

BCLP

Anti-Corruption Enforcement Webinar: 2018 in Review

BCLP on

Anti-Corruption enforcement remained a top priority in France, the UK, and the US in 2018. Join our firm's Global Anti-Corruption Team as they explain and analyze these three countries' anti-corruption enforcement efforts and...more

Thomas Fox - Compliance Evangelist

The NPA; The Petrobras FCPA Enforcement Action: Part III

This blog post concludes my multi-part exploration of the Petróleo Brasileiro S.A. – Petrobras (Petrobras) Foreign Corrupt Practices Act (FCPA) enforcement action. Today we consider the stunning result achieved by Petrobras –...more

Pillsbury Winthrop Shaw Pittman LLP

DOJ to Coordinate FCPA Enforcement With Foreign Law Enforcement Agencies

New policy seeks to reduce the burden of navigating anti-corruption investigations and enforcement actions by multiple authorities. The new DOJ policy seeks to increase coordination on FCPA and related anti-corruption...more

Thomas Fox - Compliance Evangelist

CCO Authority and Independence

Why is the focus on the CCO role now concerned with authority and independence? The role of the Chief Compliance Officer (CCO) has steadily grown in stature and prestige over the years....more

Thomas Fox - Compliance Evangelist

Using Strategic Risk to Your Advantage

I am beginning to feel this week’s theme becoming all-encompassing. As hard as I might try, it looks like it will be the Houston Astros second World Series appearance. During the first one back in 2005, I was in the corporate...more

Thomas Fox - Compliance Evangelist

Book Review: The Chickenshit Club

To my mind the most significant and important book that every Chief Compliance Officer (CCO), General Counsel (GC) and compliance practitioner needs to read is The Chickenshit Club by Pulitzer Prize winning journalist Jesse...more

Thomas Fox - Compliance Evangelist

Trump and Compliance: The First 100 Days [eBook]

Since November 9, 2016 the Apocalypse has not descended (at least as of the writing of this foreword). Since that time many of the leading compliance commentators have considered what the first 100 days of the Trump...more

Thomas Fox - Compliance Evangelist

This Week in FCPA-Episode 54, the Rubber Match Edition

This week, Jay and I have a wide-ranging discussion on some of the week’s top compliance related stories. We discuss: 1. Tom reports on Compliance Week 2017? 2. If the DOJ releases new information in the form of the...more

Thomas Fox - Compliance Evangelist

New DOJ Evaluation – Valuable Document for the Compliance Practitioner: Part II

Yesterday I began a two-part series on the Department of Justice (DOJ’s) “Evaluation of Corporate Compliance Programs” (Evaluation) posted on the Fraud Section website late last week. The document is an 11-part list of...more

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