Daily Compliance News: May 19, 2025, The Definition of Corruption Edition
Day 24 | CCO authority and independence
On May 12, 2025, the Criminal Division of the U.S. Department of Justice (DOJ) revised its Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP) and Corporate Whistleblower Awards Pilot Program (Whistleblower...more
On January 10, 2024, the United States Attorney’s Office for the Southern District of New York (“SDNY”) introduced the SDNY Whistleblower Pilot Program (“Pilot Program”), aimed at encouraging individuals to disclose...more
On November 28–30, 2023, the American Conference Institute’s 40th International Conference on the Foreign Corrupt Practices Act (“FCPA”), held in Washington, D.C., brought together prosecutors, regulators, corporate...more
Last week, Albemarle Corporation (Albemarle), a publicly traded specialty chemicals manufacturing company headquartered in North Carolina, agreed to pay more than $218 million to resolve investigations by the U.S. Department...more
Albemarle Corporation (Albemarle), a specialty chemicals manufacturing company located in Charlotte, North Carolina, agreed to pay more than $218 million to settle FCPA investigations with DOJ and the SEC stemming from...more
On December 13, 2019, the Department of Justice (“DOJ”) released an updated Export Control and Sanctions Enforcement Policy for Business Organizations (“Policy”), revising the prior policy governing voluntary self-disclosures...more
The Situation: The U.S. Department of Justice ("DOJ") has issued guidance revising its 2016 voluntary disclosure policy to provide companies stronger incentives to voluntarily self-report apparent potentially willful trade...more
We continue this multipart exploration of the recent announcement of the Fresenius Medical Care AG & Co. KGaA (FMC) Foreign Corrupt Practices Act (FCPA) enforcement action....more
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