Popular, Foreign Corrupt Practices Act (FCPA), Internal Controls

FCPA Compliance Report: Navigating Corporate Scandals: Insights on Governance, Compliance, and Recovery with Steve Vincze

Thomas Fox - Compliance Evangelist on 8/4/2025

Welcome to the award-winning FCPA Compliance Report, the longest running podcast in compliance. In this episode I welcome back Steve Vincze back to discuss the recent corporate scandal involving executives from Astronomer. ...more

What Every Multinational Company Needs to Know About...Implementing an International Compliance Program (Part III)

Foley & Lardner LLP on 1/4/2024

We have received several requests for a list of the compliance policies that make sense for every multinational company. So, as a follow-up to our earlier two posts providing “twelve steps to international compliance” (see...more

Episode 276 -- Review of Phillips and Franks Int'l SEC FCPA Settlements

The Volkov Law Group on 5/29/2023

The SEC recently announced two separate FCPA SEC enforcement actions -- the first against Franks International for $8 million for FCPA violations in Angola; and the second against Philips, a Dutch medical device company, for...more

[Event] Summit on Anti-Corruption & Compliance Programs - March 22nd - 23rd, Mexico City, Mexico

American Conference Institute (ACI) on 2/22/2023

Hosted by American Conference Institute, the Mexico Summit on Anti-Corruption & Compliance Programs returns for another exciting year with curated programming that shines a global spotlight on anti-corruption compliance...more

[Event] FCPA & Anti-Corruption for the Life Sciences Industry - July 21st - 22nd, Boston, MA

American Conference Institute (ACI) on 6/21/2022

ACI is excited to welcome you back in-person to the 14th Advanced Forum on FCPA & Anti-Corruption for the Life Sciences Industry, taking place on July 21–22, 2022 in Boston! Legal and compliance professionals from...more

Corruption, Crime & Compliance - Episode 208 - A Deep Dive into the WPP FCPA SEC Settlement

Thomas Fox - Compliance Evangelist on 10/8/2021

In this episode, Michael Volkov reviews the WPP SEC FCPA settlement. WPP, the Largest Global Advertising Group, Settles FCPA Charges with SEC for $19.2 Million. After a long hiatus, the SEC announced a settlement with WPP...more

The Berko FCPA Resolution – Lessons on Corrupt Deal Making

Thomas Fox - Compliance Evangelist on 6/25/2021

This week, the Securities and Exchange Commission (SEC) obtained a Final Judgment against Asante Berko, former employee of a Goldman Sachs subsidiary, for, as noted in the SEC Press Release, his role in orchestrating a...more

World Acceptance Corporation Settles FCPA Charges with the SEC for $21.7 Million

The Volkov Law Group on 8/11/2020

World Acceptance Corporation (“WAC”), a US-based consumer loan company, agreed to pay the SEC $21.7 million for FCPA violations in Mexico. WAC’s cited violations covered the full gamut of FCPA violations, including bribery...more

Novartis FCPA Enforcement Action: Fines, Penalties and the Cost of Recidivism

Thomas Fox - Compliance Evangelist on 7/1/2020

This week I am reviewing the Foreign Corrupt Practices Act (FCPA) enforcement action involving the Swiss pharmaceutical company Novartis AG, its Greek subsidiary Novartis Hellas S.A.C.I. (Novartis Greece) and Alcon Pte Ltd.,...more

Novartis and Alcon FCPA Enforcement Action: Lessons Learned (Part III of III)

The Volkov Law Group on 7/1/2020

At the outset, Novartis is “lucky” – the settlement is relatively positive, despite its 2016 SEC enforcement action in China. Given Novartis weak culture of compliance (if anything, a better description may be a culture of...more

Novartis FCPA Enforcement Action: Internal Controls

Thomas Fox - Compliance Evangelist on 6/30/2020

This week I am reviewing the Foreign Corrupt Practices Act (FCPA) enforcement action involving the Swiss pharmaceutical company Novartis AG, its Greek subsidiary Novartis Hellas S.A.C.I. (Novartis Greece) and Alcon Pte Ltd.,...more

ENI Pays SEC $24.5 for FCPA Violations

The Volkov Law Group on 4/24/2020

Despite the COVID-19 pandemic crisis, the SEC is continuing its FCPA enforcement activities. The SEC lawyers and staff have brought two cases recently – an enforcement action against a former Goldman Sachs executive and the...more

Walmart FCPA Settlement Shines Light On Corporate Compliance Programs

Burr & Forman on 6/21/2019

June 20, 2019 – Walmart (NYSE: WMT) and its subsidiary, WMT Brasilia, agreed to a combined criminal penalty and disgorgement of $282M, together with WMT’s criminal guilty plea and undertakings in an NPA, to reach a global...more

Understanding the DOJ’s Updated Guidance on Corporate Compliance Programs

Jones Day on 5/14/2019

The Situation: On April 30, 2019, the U.S. Department of Justice ("DOJ") released an updated version of its guidance document, "Evaluation of Corporate Compliance Programs," in an effort to "better harmonize" the document...more

SEC Settles FCPA Charges Against Ex-Panasonic Avionics Officers

The Volkov Law Group on 1/11/2019

On December 19, 2018, the SEC announced settlements with two former senior executives of Panasonic Avionics Corporation. In April 2018, Panasonic Avionics settled FCPA charges with the Justice Department and the SEC and...more

Goldman Sachs and the 1MDB Criminal Prosecutions

The Volkov Law Group on 11/6/2018

The 1Malaysia Development Berhad scandal (“1MDB scandal”) has been making headlines for the past few years. The turning point for US prosecutors was the cooperation of Malaysian law enforcement and the corruption allegations...more

Petrobras Agrees to Pay More Than $1.8 Billion for Facilitating FCPA Violations

Holland & Knight LLP on 10/18/2018

• 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

CEO Falls to SEC FCPA Settlement

The Volkov Law Group on 10/9/2018

Companies have definitely matured in the development and implementation of their ethics and compliance programs. Whether the pace has been rapid enough or is too slow, that is a debatable issue. A good litmus test for a...more

Sanofi Coughs Up $25 Million to Settle SEC FCPA Charges

The Volkov Law Group on 9/18/2018

Well, add another pharmaceutical company to the FCPA healthcare “sweep.” Frankly, the term “sweep” makes it sound like a coordinated enforcement effort – instead, it is more accurate to think of it as multiple prosecutions...more

Compliance into the Weeds-Episode 51, the PCAOB and Compliance

Thomas Fox - Compliance Evangelist on 8/23/2017

In this episode, Matt Kelly and I take a deep dive into the Public Accounting Oversight Board (PCAOB). We consider the role of the PCAOB in both audit standards and internal controls for compliance. What is goodwill, goodwill...more

COMPLIANCE INTO THE WEEDS-EPISODE 48-THE HALLIBURTON FCPA ENFORCEMENT ACTION

Thomas Fox - Compliance Evangelist on 8/2/2017

In this episode, Matt Kelly and I explore last week’s announcement by the Securities and Exchange Commission (SEC) of the resolution of its outstanding Foreign Corrupt Practices Act (FCPA) enforcement action with Halliburton...more

Lessons in Failures of Internal Controls

Thomas Fox - Compliance Evangelist on 7/31/2017

Last week’s announcement by the Securities and Exchange Commission (SEC) of the resolution of its outstanding Foreign Corrupt Practices Act (FCPA) enforcement action with Halliburton Company continues to resonate and provide...more

Day 4 Of One Month To Better Investigations And Reporting-Triage Of Allegations

Thomas Fox - Compliance Evangelist on 6/6/2017

One of the things that I learned from the television series M*A*S*H was the need for triage. In the hospital setting, triage is the process of determining the priority of patients’ treatments based on the severity of their...more

Rolls-Royce Global Enforcement Action: Part I

Thomas Fox - Compliance Evangelist on 1/18/2017

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

Mondelez FCPA Enforcement Action — An Abuse of Prosecutorial Discretion?

The Volkov Law Group on 1/17/2017

The first FCPA enforcement action for 2017 landed with very little fanfare. The SEC reached a settlement with Mondelez International for $13 million. The facts surround the hiring of an agent in India and the failure of...more

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