Wait, that’s covered? Insurability of Fines and Penalties Flowing From a Cybersecurity Breach
FCPA Compliance and Ethics Report-Episode 31-the FCPA Year in Review, Corporate Enforcement Actions
FCPA Compliance and Ethics Report-Episode 30-Interview with the FCPA Professor-Part 2
Condo complaints not in writing?
Health Data on Leased Photocopier Costs Company $1.2m—What Others Can Learn
Without fanfare, the Department of Justice (DOJ or the Department) has published a memorandum revising its policy on when – and how – it will give credit to companies for fines and other payments made to other agencies,...more
Illinois Senate President Don Harmon faces potential $9.8 million fine for improperly accepting campaign cash - “State election officials have informed Senate President Don Harmon that he will face more than $9.8 million in...more
The Dutch Public Prosecution Office ("DPPO") has introduced a new policy (aanwijzing), effective 1 January 2025, outlining conditions and fine reductions for self-disclosure, cooperation and self-investigation in corporate...more
The Justice Department is encouraging companies to voluntarily disclose criminal violations — “Come in and confess” and DOJ offers promises of a declination. But even a declination comes with a requirement — the company has...more
OFAC announced only one settlement in the first three months of 2023. Given its ongoing role in the implementation and enforcement of Russia Sanctions, OFAC’s enforcement record so far is completely understandable. The...more
If there ever is an example of a rotten corporate culture, Wells Fargo sits at the head of the class. Since Wells Fargo’s sales pressure scandal, Wells Fargo has continued to suffer from a string of scandals and misconduct. ...more
The Justice Department continues to push an aggressive agenda against businesses. It is committed to demonstrating its resolve to prosecute companies and individuals from the business community. Whether it is antitrust,...more
The Department of Justice and the Securities and Exchange Commission reached a $41 million settlement with GOL Linhas Aéreas Inteligentes S.A. (“GOL”) to resolve criminal and civil foreign bribery charges....more
In this third edition of October HorrorFest 2020 celebration we consider the first Hammer film sequel (and second in the series) – The Revenge of Frankenstein which was released in 1958. It begins as the Curse of Frankenstein...more
In its continuing aggressive FCPA criminal enforcement program, DOJ announced the indictment of two former Alstom executives and a former Marubeni executive with FCPA violations arising from a bribery scheme in Indonesia....more
On December 6, 2019, Telefonaktiebolaget LM Ericsson (Ericsson or the Company), resolved long-running investigations by the U.S. Department of Justice (DOJ) and the U.S. Securities and Exchange Commission (SEC) into the...more
Welcome to the 2020’s. The past decade helped shape both Foreign Corrupt Practices Act (FCPA) enforcement and corporate compliance programs. 2019 FCPA enforcements bore out many of the developments from the preceding years of...more
Nine years ago today, on November 4, 2010, was Panalpina Settlement Day which made history for the single largest number of companies to simultaneously settle Foreign Corrupt Practices Act (FCPA)-related violations. It was...more
Standard Chartered Bank certainly has its troubles. You know a company is in trouble, however, when it breathes a sigh of relief after paying nearly $1.1 billion in fines and penalties and compares itself to BNP Paribas, the...more
SEA View: Our new monthly periodical has launched! From April 2019, this periodical will feature investigation, compliance, and regulatory developments in Southeast Asia (SEA). For a twelve-month spell, one monthly article...more
This blog post will begin a multi-part exploration of the Petróleo Brasileiro S.A. – Petrobras (Petrobras) Foreign Corrupt Practices Act (FCPA) enforcement action. The action was a stunning reminder of the costs of endemic...more
ANTICORRUPTION DEVELOPMENTS - Linde Group Receives DOJ Declination Pursuant to FCPA Pilot Program - On June 16, 2017, German based chemical and gas company Linde Group’s American affiliates, Linde North America Inc....more
A most “daring act” seems to be a good way to introduce a multi-part look at the recent Foreign Corrupt Practices Act (FCPA) enforcement action involving the Chilean chemicals and mining company Sociedad Química y Minera de...more
When most people across the globe think of Rolls-Royce, one word comes to mind – excellence. Yet that image largely relates to Rolls-Royce Limited, the automobile manufacturer, which was founded in 1909. Just a few years...more
Yesterday I began an exploration of the General Cable Corporation (General Cable) Foreign Corrupt Practices Act (FCPA) enforcement action. It was settled with the DOJ via a Non-Prosecution Agreement (NPA) and the SEC via a...more
The Department of Justice (DOJ) and Securities and Exchange Commission (SEC) continued their stunning run of 2016 Foreign Corrupt Practices Act (FCPA) enforcement actions right up to the end of the year with the announcement...more
Just when you were thinking things could not get any bigger after the Odebrecht/Braskem Foreign Corrupt Practices Act (FCPA) enforcement action, the Department of Justice (DOJ) and Securities and Exchange Commission (SEC)...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
For the first time, the Securities and Exchange Commission has brought an FCPA enforcement action premised entirely on a one-time charitable contribution. On September 20, 2016, the SEC announced a settled FCPA...more
The enforcement action against manufacturer Nu Skin Enterprises highlights the risks of making charitable donations in high-risk countries without conducting meaningful anticorruption due diligence....more