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White Collar Crimes Foreign Official

Dorsey & Whitney LLP

Should Your Company Shut Down Its Anti-Corruption Compliance Program and Start Paying Bribes? Here Are a Few Reasons to Think...

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On February 10, 2025, President Trump issued a new Executive Order (“EO”) titled “Pausing Foreign Corrupt Practice Act Enforcement to Further American Economic and National Security.” This EO comes on the tail of Attorney...more

Latham & Watkins LLP

Former Aide to Madagascan President Sentenced for Soliciting Bribes From UK-Based Company

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The sentencing of Romy Andrianarisoa, the first ever foreign public official to be convicted under the Bribery Act 2010, provides important takeaways. On 10 May 2024, Romy Andrianarisoa was sentenced to three-and-a-half...more

BakerHostetler

The Lines Are Open! DOJ Adds New Tool in Anticorruption Efforts With Whistleblower Pilot Program

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Building on the recent passage of the Foreign Extortion Prevention Act (FEPA), at the American Bar Association’s 2024 National Institute on White Collar Crime conference in San Francisco earlier this month (2024 ABA...more

The Volkov Law Group

Former Stericyle Official Charged in Foreign Bribery Scheme

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According to the terms of a superseding information made public by the U.S. Attorney’s Office for the Southern District of New York on or about February 13, 2024, Mauricio Gomez Baez (“Baez”)—a former Stericycle executive for...more

Whiteford

Client Alert: Foreign Extortion Prevention Act

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FEPA contains a broad prohibition on corrupt activity and applies to a broad category of public officials. First, FEPA makes it unlawful for any foreign official to “demand, seek, receive, accept, or agree to” receive...more

Benesch

FEPA: The latest hammer in the DOJ’s anti-bribery toolbelt

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On December 22, 2023, President Biden completed the proverbial “sandwich” against international bribery schemes by signing the groundbreaking Foreign Extortion Prevention Act (“FEPA”) into law....more

Fisher Phillips

The Long Arm of the Law Just Got Longer: 5 Things Businesses Need to Know About the Foreign Extortion Prevention Act

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U.S. companies that do business globally may need to update their compliance training to ensure employees operating in international venues understand new risks. For decades, the Foreign Corrupt Practices Act has made it...more

Skadden, Arps, Slate, Meagher & Flom LLP

Foreign Extortion Prevention Act Criminalizes Demand-Side Bribery

On December 22, 2023, President Biden signed into law the Foreign Extortion Prevention Act (FEPA) as part of the fiscal year 2024 National Defense Authorization Act. FEPA criminalizes demand-side bribery by foreign officials...more

The Volkov Law Group

Congress Passes Foreign Extortion Prevention Act in Effort to Address “Demand-Side” of Foreign Bribery Equation

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On December 14, 2023, Congress passed the Foreign Extortion Prevention Act (“FEPA”) in an effort to address certain deficiencies inherent in the current iteration of the Foreign Corrupt Practices Act (“FCPA”), as part of the...more

Alston & Bird

Expanding U.S. Prosecutors’ Anti-Corruption Toolkit: FEPA Is Signed into Law

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Signed into law on December 22, 2023, the Foreign Extortion Prevention Act (FEPA) signals a further focus by the U.S. government on anti-corruption enforcement. Our White Collar, Government & Internal Investigations Team...more

Womble Bond Dickinson

The Foreign Extortion Prevention Act: Bribe-Soliciting Foreign Officials May Soon Be Subject To Criminal Penalties

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On December 14, 2023, the United States House and Senate passed the National Defense Authorization Act (NDAA), which included the Foreign Extortion Prevention Act (FEPA). This bipartisan legislation, which Senator Sheldon...more

WilmerHale

Congress Enacts the Foreign Extortion Prevention Act Targeting Foreign Officials' Conduct

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On December 14, 2023, the U.S. Congress (Congress) passed the Foreign Extortion Prevention Act (FEPA), as a part of the Fiscal Year 2024 National Defense Authorization Act. The FEPA, which received bipartisan support, makes...more

The Volkov Law Group

U.K. Reinsurance Bribery Scheme — the Critical Role Played by the Third-Party Intermediary (Part II of III)

The Volkov Law Group on

As I always say, the factual underpinnings of every FCPA enforcement action provides important insights into bribery schemes.  At the core of every scheme is the misappropriation of money from the company coffers for improper...more

The Volkov Law Group

DOJ’s Latest Opinion Release Underscores Absence of Corrupt Intent and Lack of Business Purpose

The Volkov Law Group on

The Justice Department has had a slow year in FCPA enforcement (another profound grasp of the obvious).  The reasons for this may be a question of timing elements in the pipeline of cases....more

The Volkov Law Group

Lessons Learned from the Albemarle FCPA Enforcement Action: Mind Your Third Parties (Part III of III)

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The Albemarle FCPA enforcement action was announced at a good time.  This year has been a slow year for DOJ’s FCPA enforcement program, although there are several months before the end of the year. The SEC, on the other hand,...more

The Volkov Law Group

FCPA Opinion Release Provides Guidance on Payment of Travel and Other Expenses for Foreign Government Officials

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The Justice Department’s Opinion Release procedure has provided important guidance over the years.  The library of Opinion Release letters is well-organized and accessible to the legal and compliance community....more

Freeman Law

The Foreign Corrupt Practices Act

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The Foreign Corrupt Practices Act (FCPA), 15 U.S.C. §§ 78dd-1, et seq was signed into law in 1977 by President Jimmy Carter. The FCPA generally prohibits payments to foreign government officials in order to obtain or retain...more

WilmerHale

OECD Recommendation Encourages Demand Side Bribery Enforcement

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On 9 December, to mark International Anti-Corruption Day, the OECD launched the snappily-named 2021 Recommendation for Further Combating Bribery of Foreign Public Officials in International Business Transactions (“the...more

Womble Bond Dickinson

Administration's Anti-Corruption Efforts Likely to Yield Greater FCPA Enforcement in Latin America and Beyond

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On June 3 of this year, the Biden Administration made plain its commitment to fighting corruption around the world, releasing a document identifying the fight against corruption “as an economic and national security priority”...more

Jones Day

New Guidance for Dutch Prosecutor on the Investigation and Prosecution of Foreign Corruption

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On October 1, 2020, the new Instruction on the Investigation and Prosecution of Foreign Corruption for the Dutch Public Prosecution Service ("DPPS") entered into force, indicating certain factors that play a role in...more

Thomas Fox - Compliance Evangelist

J&F – The Bribery Schemes

Last week, I began a multi-part exploration of one world’s largest anti-corruption enforcement actions, the J&F Investimentos SA (J&F) matter. It involved huge fines and penalties in both Brazil and the United States. Of...more

Thomas Fox - Compliance Evangelist

Sargeant Marine – The Individual Guilty Pleas

We rarely have seen a single Foreign Corrupt Practices Act (FCPA) enforcement action generate so many individual criminal pleas. The Sargeant Marine Inc. (Sargeant Marine) case is an exception. To date, there have been six...more

The Volkov Law Group

Revised FCPA Guidance: Legal Issues and Clarifications (Part IV of V)

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FCPA practitioners often debate whether the FCPA is “clear” or “ambiguous.”  Like all important issues in life (assuming this is important), the answer really depends on the specific language.  Congress’ ability to write...more

Barnea Jaffa Lande & Co.

The Offense of Bribery

Enforcement authorities have attempted in recent years to increase their war on bribery and corruption. We therefore have seen a number of elected officials investigated for such offenses, viewed as some of the most serious...more

Dorsey & Whitney LLP

UPDATE: Trial Court Overturns Former Alstom Executive’s Foreign Corrupt Practices Act Convictions

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Former Alstom SA executive Lawrence Hoskins’s jury convictions under the Foreign Corrupt Practices Act (“FCPA”) were set aside on February 26, 2020, by Judge Janet Bond Arterton of the United States District Court for the...more

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