The Line Between Gift Giving and Bribery
The New Cold War: Risk, Sanctions, Compliance Episode 21: "Interview with Drago Kos of the OECD Working Group on Bribery"
Dr. Jan Spafke and Jad Mhanna on Compliance in Non-Western Cultures
Corruption, Crime & Compliance - Episode 208 - A Deep Dive into the WPP FCPA SEC Settlement
Anti-Corruption Compliance and Enforcement Trends in the US and Globally
Doing Business in the European Union | Global Laws & Compliance Program
Gary Kalman on Corruption and Compliance Programs
Integrity Matters: Assessing the Corporate Compliance Climate in 2021-Anti-Bribery and Anti-Corruption Enforcement in 2021
Compliance Perspectives: Risk and the 2020 Compliance & Ethics Institute
Applying Behavioral Science to Compliance – A Conversation with Richard Bistrong, Front-Line Anti-Bribery LLC
Episode 119 -- The Ericsson FCPA Settlement
FCPA Compliance Report-Episode 346, Mike Skopets on Miller’s Summer 2017 FCPA Report
FCPA Compliance Training That's About the 'What Happens' at the Front-lines
FCPA Compliance Report-Episode 329, James Koukios
FCPA Compliance Report-Episode 302-Carlos Ayers on the Odebrecht Settlement from Brazil
How Can We Develop Anti-Bribery Ambassadors?
Joe Spinelli on the Kroll-Ethisphere Anti-Bribery & Corruption Report
Anti-Bribery and Compliance Challenges Ahead
What is the Current State of Anti-Bribery Compliance & Enforcement in Australia?
FCPA Compliance and Ethics Report-Episode 149-Patrick Taylor of Oversight Systems on developments in transaction monitoring
An amendment to South Africa’s Prevention and Combating of Corrupt Activities Act (PRECCA) in April 2024 has created a new criminal offense relating to the failure by members of the private sector or state-owned entities...more
Earlier this year, Australia enacted the Crimes Legislation Amendment (Combatting Foreign Bribery) Act 2024 (the Act) in an attempt to strengthen the country’s anti-bribery and corruption regime. The Act, which overhauls...more
On May 10, 2024, Romy Andrianarisoa, former Chief of Staff to the President of Madagascar, was convicted for soliciting bribes from Gemfields Group Ltd (Gemfields), a UK-based mining company specializing in rubies and...more
The Development: After an interruption during the COVID-19 pandemic, authorities across the Asia-Pacific region have fully revived dawn raids....more
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
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
In the first major action of 2024, the Department of Justice (DOJ) announced it had entered into a three-year deferred prosecution agreement (DPA) with a publicly traded global software company for alleged violations of the...more
Foreign Corrupt Practices Act (“FCPA”) enforcement continues to slowly rebound from pre-pandemic levels. In 2023, the Department of Justice (“DOJ”) and the Securities and Exchange Commission (“SEC”) resolved 13 corporate FCPA...more
This week we are taking a deep dive into the SAP Foreign Corrupt Practices Act (FCPA) enforcement action. In it, SAP agreed to pay the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) approximately...more
Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption law and enforcement developments from the past...more
When it comes to FCPA enforcement and expectations, DOJ has moved the goalposts. Some would argue that DOJ has been consistent all along. The truth, like most issues, lies somewhere between the extremes....more
The Justice Department’s FCPA enforcement record for 2024 was slow. This trend was unexpected, contrary to my own predictions and of various other prognosticators. It is hard to explain why this slowdown occurred....more
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
2023 was a very significant year for every compliance practitioner and compliance program. While there was a paucity of corporate enforcement actions under the Foreign Corrupt Practices Act (FCPA), there were significant...more
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
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
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
UN Corruption Convention’s Ratification - In October 2003, the General Assembly officially ratified the United Nations Convention against Corruption (“Corruption Convention”). Since that time, a total of 190 countries have...more
Summary - The Department of Justice (DOJ) has created the International Corporate Anti-Bribery initiative (ICAB), which aims to strengthen the United States’ global efforts in combating corruption through enhanced...more
While the Department of Justice (DOJ) has initiated at least two new Foreign Corrupt Practices Act (FCPA) enforcement actions against U.S. companies, it has also announced several decisions not to prosecute—most recently...more
Survey: Tech gaps, third parties pose biggest ABAC threats - Compliance professionals surveyed regarding their anti-bribery and corruption efforts (ABAC) indicated resource support deficiencies in areas including staffing...more
On August 10, 2023, the U.S. Securities Exchange Commission (“SEC”) and the Department of Justice (“DOJ”), in coordination with Columbian authorities, announced that Colombian conglomerate Grupo Aval Acciones y Valores S.A...more
Ericsson, a multinational telecommunications company, based in Sweden, settled its breach of its 2019 Deferred Prosecution Agreement, agreed to enter a guilty plea and pay a $206 million penalty. In 2019, Ericsson entered...more
While Foreign Corrupt Practices Act (FCPA) enforcement activity has not come close to returning to the heights seen a few years ago, 2022 reflected significant increases from the prior year in both the number of cases against...more