Episode 383 -- FCPA Update: Declination and Indictment
Daily Compliance News: August 19, 2025, The AI Winter Edition
FCPA Compliance Report - Episode 770 - Integrating ESG in Global Outsourcing: Insights from Inge Zwick
Compliance Tip of the Day – Final Thoughts on Pre - Acquisition Due Diligence in M&A
Compliance Tip of the Day: Key M&A Enforcement Actions
FCPA Compliance Report: Navigating Corporate Scandals: Insights on Governance, Compliance, and Recovery with Steve Vincze
FCPA Compliance Report: 10 Core Principles for Effective Internal Investigations with Michelle Peirce
FCPA Compliance Report: The Impact of Secondary Tariffs on Global Trade with Mike Huneke and Brent Carlson
Daily Compliance News: July 14, 2025, The Secret Business Sauce-Reading Edition
Daily Compliance News: July 11, 2025, The What is a COI Edition
Regulatory Ramblings: Episode 73 - Geopolitical Risk: Thai Tensions / Sanctions, Tariffs & FCPA Enforcement in Asia
FCPA Compliance Report: Stay the Course: Ellen Lafferty on Navigating Anti-Corruption Compliance in 2025
10 For 10: Top Compliance Stories For the Week Ending June 28, 2025
Upping Your Game: Crowd - Sourcing Risk Management Intelligence with AI
Episode 374 -- Justice Department Resumes FCPA Enforcement with New, Focused Guidance
2 Gurus Talk Compliance – Episode 54 – The FCPA is Back On Edition
Compliance Tip of the Day – New FCPA Enforcement Memo – What Does it Mean?
Compliance Tip of the Day: New FCPA Enforcement Memo - What Does it Say?
FCPA Compliance Report: Recent DOJ Policy Announcements
On August 7, 2025, the United States Department of Justice, Criminal Division, Fraud Section (“DOJ”) issued a declination letter to a U.S.-based insurance company (the “Company”) to resolve alleged violations of the Foreign...more
Is the DOJ really changing its playbook on FCPA enforcement, or is it business as usual under a new administration? In this episode, Michael digs into two headline developments that say a lot about where things are headed -...more
In the first FCPA declination under the Trump Administration, Liberty Mutual Insurance Company paid $4.7 million in disgorgement and received a declination letter from the Department of Justice. The declination reflects...more
DOJ is pushing hard for voluntary disclosures and urging companies to take advantage of its Voluntary Disclosure Program. The carrot is significant — a declination in exchange for cooperation, remediation and disgorgement....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
The Justice Department has been pushing its voluntary self-disclosure program and changes to its Corporate Enforcement Policy, in an attempt to increase FCPA enforcement cooperation. The Golden Ring for every company facing...more
A government inquiry can result in serious consequences for a company or individual. Our new podcast series, Voluntary Disclosure—brought to you by the lawyers in our investigations, enforcement, and white collar practice—is...more
On December 13, 2019, the US Department of Justice (DOJ) announced a revised Export Control and Sanctions Enforcement Policy for Business Organizations (Revised EC/S Policy), clarifying its prior guidance on voluntary...more
In a recently released letter, the Justice Department issued a declination to the Insurance Corporation of Barbados Limited (ICBL) for violations of the FCPA under the FCPA Corporate Enforcement Policy. DOJ required ICBL to...more
• The voluntary disclosure of a Foreign Corrupt Practices Act (FCPA) violation, “full cooperation” in an ensuing investigation, and timely and appropriate remediation, will create a presumption that the disclosing company...more
In a speech yesterday at the 34th International Conference on the Foreign Corrupt Practices Act, U.S. Deputy Attorney General Rod Rosenstein announced the Department of Justice’s (DOJ) revised Foreign Corrupt Practices Act...more
The Justice Department recently resolved two separate FCPA investigations under its Pilot Program. To be sure, DOJ’s resolution of these two matters reinforces the real and tangible benefits of its Pilot Program....more
This week, Jay and I have a wide-ranging discussion on some of the week’s top compliance related stories. We discuss: 1. The Kokesh case at the US Supreme Court is significant for SEC enforcement of the FCPA around profit...more
Enforcement of the Foreign Corrupt Practices Act (FCPA) remained a high priority for the Department of Justice and the Securities and Exchange Commission in 2016, resulting in more than 50 combined enforcement actions, record...more
Breaking new ground, the Department of Justice (DOJ) recently issued two “declinations with disgorgement” to two companies accused of Foreign Corrupt Practices Act (FCPA) violations. These declinations, released under the...more
Last week there were two declinations issued by Department of Justice (DOJ) for Foreign Corrupt Practices Act (FCPA) matters. The matters involved two Texas based, privately held companies. The first was HMT LLC (HMT) which...more
Tom Fox and I recorded a podcast recently on the Johnson Controls enforcement action. In our podcast we discuss a number of issues relating to the Justice Department’s decision to reward Johnson Controls with a declination....more
The U.S. Department of Justice (DOJ) issued its first set of public declinations since its April unveiling of a new self-reporting Foreign Corrupt Practices Act (FCPA) pilot program. On June 7, 2016, Akamai Technologies,...more
On April 5, 2016, the Fraud Section of the Department of Justice's (DOJ) Criminal Division issued an enforcement plan and guidance (the Guidance) laying out three steps it is taking to intensify Foreign Corrupt Practices Act...more
The U.S. Department of Justice (“DOJ”) Criminal Division yesterday announced that its Fraud Section’s Foreign Corrupt Practices Act (“FCPA”) Unit is conducting a one-year FCPA enforcement pilot program (“Program”). A company...more