Day 26 | Operationalizing compliance through payroll
Day 25 | Compliance function in an organization
Day 24 | CCO authority and independence
Day 29 of 31 Days to a More Effective Compliance Program
FCPA Compliance and Ethics Report-Episode 30-Interview with the FCPA Professor-Part 2
On June 10, 2025, the Department of Justice (“DOJ”) issued a memorandum establishing guidelines for enforcement of the Foreign Corrupt Practices Act (the “Guidelines” and “FCPA,” respectively). The DOJ issued the Guidelines...more
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
While FCPA enforcement against companies has been relatively quiet this year, despite a strong beginning to the year — the SAP case for $220 million; and the Gunvor case for $661 million — DOJ has been pushing a number of...more
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
Over the past 15 months the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) has made clear through three Foreign Corrupt Practices Act (FCPA) enforcement actions and speeches, their priorities in...more
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
Matt Galvin, Counsel, Compliance & Data Analytics at the DOJ and one of the experts leading the DOJ’s data analytics initiative, highlighted in another talk, the proactive use of data to generate cases related to the FCPA and...more
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 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
To restate the obvious – DOJ has prioritized prosecution of national security crimes. For the business world, every company touches the international economy. Even a domestic company might sell products or services outside...more
On January 17, Assistant Attorney General Kenneth A. Polite, Jr. delivered remarks at Georgetown University Law Center, during which he announced changes to the DOJ’s Criminal Division Corporate Enforcement and Voluntary...more
Contrary to the often-repeated narrative, the Justice Department is transparent about its enforcement plans and compliance expectations. Since the issuance of the FCPA Guidance in 2012, DOJ has continued to provide guidance...more
In a recently published memorandum, Deputy Attorney General (DAG) Lisa Monaco announced important updates to the U.S. Department of Justice’s (DOJ’s) approach to investigating and prosecuting corporate crimes. In the...more
In following the Justice Department and the Securities Exchange Commission FCPA enforcement actions, I am always reminded of the popular phrase — “reading the tea leaves.” (or “tasseography,” a fortune-telling method based on...more
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
On August 14, 2020, the U.S. Department of Justice (DOJ) issued its first Opinion Procedure Release (OPR) in nearly six years, OPR 20-01. OPRs allow companies to seek guidance from DOJ “as to whether certain specified,...more
It is time to break out the crystal ball for FCPA 2020 Predictions. In preparing for this, I always rely on my past admiration of Carnac the Magnificent....more
On December 13, 2019, the National Security Division (“NSD”) of the U.S. Department of Justice (“DOJ”) released a revised enforcement policy (“the Policy”) meant to encourage companies to voluntarily self-disclose potentially...more
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
On March 8, 2019, the Department of Justice (“DOJ”) released a revised version of its FCPA Corporate Enforcement Policy (the “Policy”), which provides enforcement and practice guidance to DOJ prosecutors and was formally...more
This week, in a podcast series on the Compliance Podcast Network, sponsored by Affiliated Monitors, Inc. (AMI), I visit with Vincent DiCianni, founder and President of AMI, and Eric Feldman, Senior Vice President of AMI....more
In addition to enforcement actions, the Department of Justice’s (DOJs) 2016 FCPA Pilot Program, coupled with 2017’s Evaluation of Corporate Compliance Programs (Evaluation) and the FCPA Corporate Enforcement Policy, all...more
On March 1, 2018, the Criminal Division of the U.S. Department of Justice (“DOJ”) announced that it has expanded the scope of cases in which it will consider issuing a formal declination of criminal charges for a company that...more
On March 1, 2018, John P. Cronan, the acting head of the Department of Justice’s Criminal Division, and Benjamin Singer, Chief of the Fraud Section’s Securities and Financial Fraud Unit, announced at the American Bar...more
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