10 For 10: Top Compliance Stories For the Week Ending August 23, 2025
Data Driven Compliance: The Failure to Prevent Fraud Offense: Insights for US General Counsels with Mike DeBernardis
Daily Compliance News: August 21, 2025, The Fabricated Evidence Edition
Daily Compliance News: August 18, 2025, The All Corruption Edition
10 For 10: Top Compliance Stories For the Week Ending August 16, 2025
LathamTECH in Focus: Move Fast, Stay Compliant
Daily Compliance News: August 5, 2025, The Staying Focused Edition
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
Daily Compliance News: July 24, 2025, The In Phone Hell Edition
Daily Compliance News: July 23, 2025 the Pardon in the Wind? Edition
Fox on Podcasting: Harnessing the Power of Niche
Daily Compliance News: July 17, 2025, The COSO Yanked Edition
All Things Investigation: Due Diligence and Drama: A Deep Dive into Art World with Daniel Weiner
10 For 10: Top Compliance Stories For the Week Ending, July 12, 2025
Daily Compliance News: July 9, 2025, The TACO Don Caves Again Edition
RICO Section 1962(b): Acquisition or Maintenance of Control Over Legitimate Enterprises — RICO Report Podcast
Adventures in Compliance: The Novels – The Hound of the Baskervilles, Introduction and Compliance Lessons Learned
10 For 10: Top Compliance Stories For the Week Ending June 28, 2025
The Dark Patterns Behind Corporate Scandals
As global supply chains continue to realign in response to shifting geopolitical dynamics, tariffs and trade policies, compliance and risk professionals are facing unprecedented challenges. The evolving trade landscape is...more
Criminals can be creative — that is a true statement but essentially FCPA criminals have to embrace a variety of well-established techniques to accomplish a straight-forward goal — steal money from the company to funnel...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
Hosted by American Conference Institute, the 11th Annual Advanced Forum on False Claims and Qui Tam Enforcement returns for another exciting year for lively discussions on FCA enforcement including the ramifications of two...more
Even though the size of the KT Corp. SEC enforcement action is relatively small, the underlying misconduct provides a number of important lessons learned. ...more
The SEC’s FCPA enforcement action against WPP presents a number of important lessons learned, ranging from third-party risk management, properly responding to employee complaints and red flags, and failure to integrate...more
We all know and hear about third-party risks – over and over again. Despite this recurring theme, organizations continue to pay the price for failing to address third-party issues. It does not take a rocket scientist to...more
FCPA settlement actions often underscore specific compliance risks for legal and compliance professionals. If there ever was a case where third-party risks were bungled, and even intentionally embraced, the Foster Wheeler...more
We all know it when we see it – a recurring fact pattern in which a company enlists a corrupt third party intermediary for one purpose (and one purpose only) – to pay a bribe. Let me give you a few examples....more
La Ley de Prácticas Corruptas en el Extranjero (“Foreign Corrupt Practices Act – FCPA”) prohíbe el pago de sobornos a funcionarios extranjeros para ayudar a obtener o retener negocios. Exige que las empresas cuyos valores se...more
The Foreign Corrupt Practices Act (FCPA) prohibits payment of bribes to foreign officials to assist with obtaining or retaining business. It requires companies whose securities are listed in the US to maintain books and...more
Last week the Justice Department (DOJ) announced a resolution of the long standing Foreign Corrupt Practices Act (FCPA) enforcement action involving Telefonaktiebolaget LM Ericsson (Ericsson), a multinational networking and...more
Ericsson’s FCPA settlement is in the books (not the books and records). But it casts a significant shadow across the FCPA landscape. A pervasive and systemic culture of bribery is defined to reflect senior executive...more
Internal controls are a key tool to operationalize your third-party risk management program. The basic internal controls, that should be a part of any financial controls system. There were four significant controls the...more
We are at the end of my exploration of the long-awaited Fresenius Medical Care AG & Co. KGaA (FMC) Foreign Corrupt Practices Act (FCPA) enforcement action. ...more
I continue my multipart (not quite sure how long it will go) exploration of last week’s announcement of the Fresenius Medical Care AG & Co. KGaA (FMC) Foreign Corrupt Practices Act (FCPA) enforcement action. It involved...more
Last week, the long-awaited Fresenius Medical Care AG & Co. KGaA (FMC) Foreign Corrupt Practices Act (FCPA) enforcement action was announced. It involved massive multi-year and multi bribery schemes by the company in multiple...more
Fresenius Medical’s FCPA settlement for $231 million demonstrates again the continuing vitality surrounding the FCPA Corporate Enforcement Policy – which provides a carefully constructed framework for encouraging voluntary...more
The Cognizant FCPA enforcement action will go down as a problematic resolution for the policy reasons mentioned in my last post. Putting those concerns aside, there are some important lessons learned and observations that...more
The Cognizant bribery scheme is another in the line of illegal conspiracies orchestrated by senior management – but this one is even more disturbing for a number of reasons. ...more
The Department of Treasury’s Office of Foreign Asset Control (“OFAC”) recently announced the settlement of the Epsilon enforcement action. This case requires a theme song and there is none better than Trucking from Grateful...more
After a lengthy investigation conducted by the SEC, Beam Suntory agreed to pay $8 million to settle FCPA violations in India. Beam’s settlement took over 5 years from initial disclosure to resolution – a long-time to say the...more
Sometimes it takes a large enforcement action to underscore basic and important anti-corruption compliance principles. The Société Générale enforcement action demonstrated two important principles – the dangers of a weak...more