Moving Beyond the Usual Helpline Data
FCPA Compliance Report: 10 Core Principles for Effective Internal Investigations with Michelle Peirce
10 For 10: Top Compliance Stories For the Week Ending, July 26, 2025
Great Women in Compliance: The Compliance Influencer with Bettina Palazzo
Adventures in Compliance: Investigate Lessons from A Study in Scarlet
What the Board Should Be Asking About the Compliance Program
Common Scenarios Triggering False Claims Act Violations, Part 3: Claims and Investigations
False Claims Act Insights - The Art and Science of Corporate Compliance in Managing FCA Risk
An Ounce of Prevention: Keys to Understanding and Preventing AI and Cybersecurity Risks
Behavioral Health Compliance
The Justice Insiders Podcast: Using External Resources for Internal Investigations
Bank Investigations and Enforcement Actions: Lessons Learned — The Consumer Finance Podcast
The Justice Insiders Podcast: SEC Plays Chicken with Jarkesy
What Nonprofit Board Leadership Needs To Know About Internal Investigations
Compliance Series Part 3: Ensuring Compliance Programs are Effective
Compliance Programs Part 2: Designing a Successful Compliance Program
Compliance Programs Part 1: What is a Compliance Program and Why do Businesses Need One?
How to Combat Corporate Theft: Office Space - Hiring to Firing Podcast
All Things Investigations: Episode 28 - New French Anti-Corruption Investigative Guidance with Anne Gaustad and Bryan Sillaman
Investigative Power: Utilizing Self Service Solutions for Internal Investigations?
Internal investigations have long been a valuable tool for companies and their executives to manage civil, regulatory, and criminal liability. By investigating potential corporate misconduct with the help of counsel, a...more
Issued on February 10, 2025, Executive Order 14209 (“Pausing Foreign Corrupt Practices Act Enforcement To Further American Economic and National Security”) called on the Department of Justice (DOJ) to “review guidelines and...more
ACI's Global Anti-Corruption, Ethics & Compliance – New York is your best opportunity to hear how companies are addressing the status of DOJ and SEC priorities, effective compliance and risk strategies, strengthening...more
On August 1, 2024, the Department of Justice (DOJ) issued final guidance on its Corporate Whistleblower Awards Pilot Program (Program), offering financial incentives to qualifying individuals who report certain criminal...more
To what extent are boards and senior executives in your country of focus taking proactive steps to reduce incidences of fraud and corruption from surfacing within their company? Over the past several years, there has been...more
This is not your typical FCPA enforcement action Lessons Learned column. Instead, Ericsson’s breach of its DPA presents a laundry list of internal investigation errors – as a practitioner in this area, this is the nightmare...more
On June 2, the French ministry of Justice released a new order addressed to French prosecutors on the criminal policy relating to international corruption and how such cases should be handled. In this order, which...more
The European Union (“EU”) recently has grappled with a series of massive money laundering scandals and strategized about how to more effectively combat international money laundering and corruption. Generally, the EU has...more
The Justice Department has been criticized on numerous occasions about its approach to criminal investigations and prosecutions. In a recent decision, the chief judge in the Eastern District of New York criticized DOJ for...more
The big one finally is resolved. The long-awaited Walmart Inc. (Walmart) Foreign Corrupt Practices Act (FCPA) enforcement action was announced yesterday. This massive case came in with multiple documents, a long list of...more
On April 30, 2019, Brian A. Benczkowski, the assistant attorney general for the Criminal Division of the United States Department of Justice, announced the release of an updated version of the Criminal Division’s guidance for...more
The Justice Department’s new Corporate Compliance Guidance is keyed to the concept of a “well-designed compliance program.” Under this concept, we first examined risk assessments and policies and procedures. ...more
Fresenius Medical, the largest supplier of dialysis equipment and services agreed to pay $231 million to the Justice Department and the SEC to resolve FCPA violations in 17 countries in Africa, the Middle East and Europe....more
• Four years ago, Brazilian authorities began Operation Car Wash, a wide-ranging and still ongoing corruption and money laundering investigation that has spanned 11 countries. • The fallout continues with a recent U.S....more
This blog post concludes my multi-part exploration of the Petróleo Brasileiro S.A. – Petrobras (Petrobras) Foreign Corrupt Practices Act (FCPA) enforcement action. Today we consider the stunning result achieved by Petrobras –...more
ANTICORRUPTION DEVELOPMENTS - $34 Million SEC Settlement for Legg Mason - On August 27, 2018, the Securities and Exchange Commission (SEC) announced that Legg Mason Inc. will pay more than $34 million to settle an...more
The United States Department of Justice, the U.S. Securities and Exchange Commission, and non-U.S. governments and agencies have recently emphasized their continued commitments to pursuing both corporate and individual...more
Properly Scoped Investigation by Qualified Personnel – How has the company ensured that the investigations have been properly scoped, and were independent, objective, appropriately conducted, and properly documented? These...more
Your company should have a detailed written procedure for handling any complaint or allegation of bribery or corruption, regardless of the means through which it is communicated. The mechanism could include the internal...more
The call, email or tip comes into your office; an employee reports suspicious activity somewhere across the globe. That activity might well turn into a Foreign Corrupt Practices Act (FCPA) issue for your company. As the Chief...more
ANTICORRUPTION DEVELOPMENTS – Former Magyar Telekom Executives Settle Bribery Charges – On April 24, 2017, the Securities and Exchange Commission (SEC) announced that two former executives of Magyar Telekom, a...more
Today I conclude my two-part series on the recent Foreign Corrupt Practices Act (FCPA) enforcement action involving the Chilean chemicals and mining company Sociedad Química y Minera de Chile (SQM), which agreed to pay a...more
Yesterday I began a two-part series on the Department of Justice (DOJ’s) “Evaluation of Corporate Compliance Programs” (Evaluation) posted on the Fraud Section website late last week. The document is an 11-part list of...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 guidance issued by the DOJ in connection with the Pilot Program and recent declinations state that disclosure, remediation and cooperation are essential to any favorable resolution with the government. Six months...more