Compliance into the Weeds: Boeing, a NPA and the End of Monitors
Understanding the Whistleblower Pilot Program in the Southern District of New York
Episode 295 -- Deep Dive into the Albemarle DOJ and SEC FCPA Settlements
Federal Monitorships and Making Them Work
Salvador Dahan on the Journey of Petrobras
Compliance Into The Weeds: DAG Announces Changes in Enforcement Priorities
FCPA Compliance and Ethics Report-Episode 134, Judge Rakoff, Judge Leon and their comments on DPAs, with the FCPA Professor
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
Lessons Learned from the Parker Drilling DPA and Ralph Lauren NPA
On February 10, President Donald J. Trump signed an executive order and accompanying fact sheet directing U.S. Attorney General (AG) Pam Bondi to pause the initiation of new investigations and enforcement actions, and to...more
Over the past 12 months or so there have been a series of Foreign Corrupt Practices Act (FCPA) enforcement actions where the respondents have changed and/or modified their sales models to get away from external third parties...more
On November 28–30, 2023, the American Conference Institute’s 40th International Conference on the Foreign Corrupt Practices Act (“FCPA”), held in Washington, D.C., brought together prosecutors, regulators, corporate...more
Albemarle Corporation (Albemarle), a specialty chemicals manufacturing company located in Charlotte, North Carolina, agreed to pay more than $218 million to settle FCPA investigations with DOJ and the SEC stemming from...more
Over the past several blog posts, I have been exploring the Albemarle FCPA enforcement action. We have explored in some detail the DOJ Non-Prosecution Agreement (NPA) and the SEC Administrative Order(Order). In this final...more
Albemarle Corporation (Albemarle), recently agreed to pay more than $218 million to resolve investigations by the U.S. Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) into violations of the...more
Last week, Albemarle Corporation (Albemarle), agreed to pay more than $218 million to resolve investigations by the U.S. Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) into violations of the...more
Last week, Albemarle Corporation (Albemarle), a publicly traded specialty chemicals manufacturing company headquartered in North Carolina, agreed to pay more than $218 million to resolve investigations by the U.S. Department...more
Brazil’s Anti-Corruption and Compliance Community Will Gather for Large, 1:1 and Smaller-Group Discussion! As the longest-standing anti-corruption and compliance gathering in Brazil, Summit on Anti-Corruption Brazil is...more
In October, Deputy Attorney General (DAG) Lisa O. Monaco gave a Keynote Address at ABA’s 36th National Institute on White Collar Crime (Monaco Speech). Her remarks reframed a discussion about the uses of, reasons for and...more
In one of the first substantive speeches on corporate criminal enforcement under the Biden administration, Deputy Attorney General Lisa Monaco announced on October 28, 2021, several immediate changes to Department of Justice...more
The Department of Justice (DOJ or Department), under the leadership of Attorney General Merrick Garland, has expressed that one of its top priorities in corporate criminal matters is “to prosecute the individuals who commit...more
The Department of Justice under the Biden Administration signaled yesterday that it will be putting more resources towards investigating corporate crime – and expecting more from companies who come under investigation. On...more
Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. Today, Matt and I have a rare emergency podcast on...more
Stephen Martin would often tell the story about when he was a Department of Justice (DOJ) prosecutor and a company would come in and claim they spent all the money they could on their corporate compliance program. Martin...more
The U.S. Government’s 2019 FCPA enforcement efforts led to new milestones; further cooperation with international authorities; and continued use of independent corporate monitors. The following are key takeaways of these...more
The Situation: The U.S. Department of Justice ("DOJ") has issued guidance revising its 2016 voluntary disclosure policy to provide companies stronger incentives to voluntarily self-report apparent potentially willful trade...more
On July 22, 2019, the United States Department of Justice (“DOJ”) and Securities and Exchange Commission (“SEC”) announced that they had resolved allegations of Foreign Corrupt Practice Act (“FCPA”) violations against...more
Initially, it would not seem that much was new or different about the Microsoft FCPA enforcement action but through this exploration, I think some clear lessons have emerge. The first is around internal controls. Here there...more
Continuing our use of great drum solos to consider the Microsoft Foreign Corrupt Practices Act (FCPA) enforcement action, today we consider what Microsoft did to obtain their result. We have previously considered the...more
Microsoft finally resolved its FCPA enforcement action with a whimper. Notwithstanding prior suggestions that Microsoft’s investigation uncovered global conduct, Microsoft’s liability focused primarily on Microsoft’s conduct...more
Recent Trends And Patterns In FCPA Enforcement - Although the DOJ and SEC brought a relatively low number of FCPA enforcement actions in the first half of 2019, an unusually large portion of those enforcement actions...more