News & Analysis as of

White Collar Crimes Internal Investigations Corruption

Carlton Fields

DOJ Policy Changes Have Made Internal Investigations More Important Than Ever

Carlton Fields on

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

Husch Blackwell LLP

DOJ Poised to Reboot FCPA Investigations and Enforcement

Husch Blackwell LLP on

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

A&O Shearman

Poland post-regime change: shifting enforcement approaches to state-owned enterprises and their business partners

A&O Shearman on

There was significant legal and regulatory scrutiny across both private and state-owned sectors in Poland in 2024, focusing on business fraud, sanctions compliance, money laundering, and bribery. State-owned enterprises,...more

A&O Shearman

White-collar crime developments in Italy: trends and developments

A&O Shearman on

There has been an increase in enforcement action and strategies relating to cybercrimes, supply-chain related offenses, VAT fraud, corruption, and money laundering. A significant shift has been prompted by the EU Corporate...more

Robinson & Cole LLP

Legal Update: DOJ Issues Final Guidance on New Whistleblower Awards Pilot Program, Placing Premium on Prompt and Detailed...

Robinson & Cole LLP on

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

Sands Anderson PC

Before Doing Your Own Workplace Investigation—a Cautionary Tale

Sands Anderson PC on

A few years ago, a friend of mine was part of an organization that received complaints about one of its leaders, which led to questions about whether the leader should be fired. The organization debated internally about what...more

J.S. Held

INDEPTH FEATURE: Corporate Fraud & Corruption 2024

J.S. Held on

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

Latham & Watkins LLP

New SFO Director Sets Tone for Tenure

Latham & Watkins LLP on

Motivated by a “visceral reaction” to large-scale economic crime, Nick Ephgrave lays out vision for a bolder, more pragmatic, and more proactive agency. Whistleblowers, dawn raids, and cross-agency collaboration are all...more

A&O Shearman

Regulators and reforms: how Australia tackled white collar crime in 2023 and what to expect in 2024

A&O Shearman on

Regulators and enforcement authorities in Australia intensified their efforts to curb white-collar crime in 2023. They targeted fraud, money laundering, tax evasion, cybercrime, and corruption across multiple industries,...more

A&O Shearman

Belgian investigations trends and developments in white collar crime

A&O Shearman on

We continue to see increased investigation and prosecution of corruption, fraud, modern slavery and workplace misconduct, especially in the construction, transportation and financial sectors. Investigations are boosted by...more

The Volkov Law Group

Lessons Learned from Ericsson’s DPA Breach: An Internal Investigation Nightmare (Part III of III)

The Volkov Law Group on

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

White & Case LLP

France encourages corporations to self-report acts of corruption without any guarantee of leniency

White & Case LLP on

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

Thomas Fox - Compliance Evangelist

Selection of Investigative Counsel

Dan Dunne, in a Compliance and Ethics Professional article, entitled “Foxes and henhouses: The importance of independent counsel”, said a critical element in any investigation is “fair and objective evaluation by the...more

Thomas Fox - Compliance Evangelist

Introduction to Internal Reporting and Investigations on 31 Days to a More Effective Compliance Program

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 FCPA issue for your company. As the CCO, it will be up to you to begin...more

Thomas Fox - Compliance Evangelist

The Astros Cheating Scandal and Compliance – Part 6: Final Thoughts on the Scarlet ‘C’

Culture and Why It Matters - For anyone who was paying attention to the Astros, it has long been clear that the team had a very insular and toxic culture. The Astros culture was broken, toxic and this culture lead directly...more

Thomas Fox - Compliance Evangelist

The Astros Cheating Scandal and Compliance – Part 5: The Whistleblower and The Amnesty

I am nearing the end of a multi-part exploration of the Major League Baseball (MLB) investigation into allegations that the Houston Astros engaged in a multi-year scheme to steal signs and signals from opposing teams. ...more

The Volkov Law Group

Quad/Graphics Settles SEC FCPA Case for Nearly $10 Million

The Volkov Law Group on

Quad/Graphics, a Wisconsin print and digital marketing company agreed to pay the SEC almost $10 million to settle FCPA charges for foreign bribery violations in Peru and China. ...more

Ballard Spahr LLP

The EU’s Efforts to Combat Money Laundering, the Financing of Terrorism and Corruption Seem to Overlook a Very American Approach:...

Ballard Spahr LLP on

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 Volkov Law Group

A Classic Criminal Investigation: Unraveling PDVSA Corruption

The Volkov Law Group on

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 Volkov Law Group

Remediate and Enhance Your Internal Investigation Program (Part III of III)

The Volkov Law Group on

An audit program of a company’s internal investigation function provides valuable insights for its internal investigation program and the company’s overall ethics and compliance program.  It is a critical part of ensuring...more

The Volkov Law Group

Improving Your Internal Investigation Program (Part I of III)

The Volkov Law Group on

In the compliance idea marketplace, there has been an increased focus on the importance of maintaining an organization’s speak up culture and the importance of a reliable and efficient internal investigation program....more

Herbert Smith Freehills Kramer

DOJ Criminal Division Releases Updated Guidance for Evaluation of Corporate Compliance Programs

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

Thomas Fox - Compliance Evangelist

The Updated Evaluation of Corporate Compliance Programs – Guidance Document: Part 5 – Reporting and Investigations

We are in an exploration of the recently released Evaluation of Corporate Compliance Programs – Guidance Document (2019 Guidance), which was announced (ECI speech) by Assistant Attorney General Brian Benczkowski at the Ethics...more

The Volkov Law Group

DOJ’s New Corporate Compliance Guidance: Training and Communications, Reporting and Investigations, Third-Party Management and...

The Volkov Law Group on

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

The Volkov Law Group

AppliChem Pays OFAC $5.5 Million for Cuba Sanctions Violations

The Volkov Law Group on

OFAC continues to pile up enforcement actions for sanctions violations. In yet another example of a failure of companies to address compliance, to follow up on compliance and to ensure ultimate compliance, AppliChem...more

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