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
Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption law and enforcement developments from the past...more
The U.S. Justice Department unveiled new policies about how it will prosecute cases of corporate misconduct, offering new incentives for companies whose misconduct includes “aggravating circumstances” to step forward and...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
For the first time since 2014, the Department of Justice’s (DOJ) Foreign Corrupt Practices Act (FCPA) Unit has issued an opinion responding to a request for advice on compliance with the anti-bribery provisions of the FCPA. ...more
On July 3, the Criminal Division of the U.S. Department of Justice (“DOJ”), and the Enforcement Division of the U.S. Securities and Exchange Commission (“SEC”) released an updated joint Resource Guide to the U.S. Foreign...more
On December 4, 2019, Assistant Attorney General Brian A. Benczkowski provided a synopsis of FCPA enforcement in 2019 to the American Conference Institute’s International Conference on the Foreign Corrupt Practices Act....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
I always take a deep breath when starting this posting – not that I am the kiss of death, but sometimes my predictions come true and most times they do not. But with that caveat, I am brave enough to venture into 2018 and...more
In a significant FCPA enforcement development, DOJ’s Deputy Attorney General (“DAG”) Rod Rosenstein last announced the implementation of a new FCPA Corporate Enforcement Policy. The announcement was not a surprise based on...more
On November 29, 2017, Deputy Attorney General Rod Rosenstein announced that the U.S. Department of Justice (DOJ) was issuing a new enforcement policy covering its enforcement of the Foreign Corrupt Practices Act (FCPA). The...more
The Justice Department has touted its efforts to bring greater transparency to FCPA enforcement. There is no question that in the last five years the Justice Department has moved the needle – the FCPA Guidance issued in 2012;...more
As its name implies, the U.S. Foreign Corrupt Practices Act (“FCPA”) was designed to prevent U.S. companies from engaging in foreign bribery. The Department of Justice (“DOJ”) and the Securities Exchange Commission (“SEC”),...more