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Compliance Foreign Corrupt Practices Act (FCPA) Corruption

Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory violations. ... more +
Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory violations.  In response to many corporate scandals evidencing rampant unethical business practices, many nations, including the United States, began passing strict regulatory frameworks aimed at curbing these abuses. Notable pieces of legislation in this area include the U.S. Foreign Corrupt Practices Act (FCPA), Sarbanes-Oxley (SOX), and the U.K. Bribery Act, to name a few. The foregoing statutes and the severe penalties often associated with them form the basis of many modern institutional compliance programs. less -
The Volkov Law Group

SEC Settles FCPA Case with Moog, Inc. for Nearly $1.7 Million

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The SEC notched another FCPA settlement, continuing its steady pursuit and resolution of FCPA cases. In the meantime, the Justice Department has been silent in the FCPA enforcement arena. In its latest settlement, Moog,...more

Thomas Fox - Compliance Evangelist

Deere FCPA Enforcement Action: Lessons on Post-Acquisition Integration and Investigation in M&A

We recently had a Foreign Corrupt Practices Act (FCPA) enforcement action that reminded me that everything old is new again in anti-corruption compliance. The Securities and Exchange Commission (SEC) FCPA enforcement action...more

Thomas Fox - Compliance Evangelist

Deere FCPA Enforcement Action: Lessons on Pre-Acquisition Due Diligence in M&A

We recently had a Foreign Corrupt Practices Act (FCPA) enforcement action that reminded me that everything old is new again in anti-corruption compliance. The Securities and Exchange Commission (SEC) FCPA enforcement action...more

Thomas Fox - Compliance Evangelist

Deere’s FCPA Enforcement Action: Performing a Root Cause Analysis to Inform Remediation

We recently had a Foreign Corrupt Practices Act (FCPA) enforcement action that reminded me that everything old is new again in anti-corruption compliance. The Securities and Exchange Commission (SEC) FCPA enforcement action...more

Thomas Fox - Compliance Evangelist

Deere’s FCPA Enforcement Action: Lessons on Corrupt Payments

We recently had a Foreign Corrupt Practices Act (FCPA) enforcement action that reminded me that everything old is new again in anti-corruption compliance. The Securities and Exchange Commission (SEC) FCPA enforcement action...more

Thomas Fox - Compliance Evangelist

Deere’s FCPA Case: Lessons on Gifts, Travel and Entertainment

We recently had a Foreign Corrupt Practices Act (FCPA) enforcement action that reminded me that everything old is new again in anti-corruption compliance. The Securities and Exchange Commission (SEC) FCPA enforcement action...more

The Volkov Law Group

Episode 339: Four Sanctions Cases Everyone Should Know

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How prepared is your organization to handle the evolving landscape of sanctions compliance? In this episode of Corruption, Crime and Compliance, Michael Volkov dives into critical sanctions compliance cases and their...more

Adams and Reese LLP

International Compliance Digest - September 2024

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New export controls, new section 301 duties, new OFAC requirements, new de minimis rule, new DOJ corporate compliance guidance, new international guidance on Russian sanctions. September had it all....more

The Volkov Law Group

“The New FCPA”: The Future Landscape of Sanctions Enforcement (Part II of IV)

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We are all familiar with — over and over — third-party risks and FCPA risks. It is drilled in our collective heads — third-party risks and bribery. Legal and compliance professionals have to learn and understand the ins...more

The Volkov Law Group

The Four Sanctions Compliance Cases that Everyone Should Know (Part I of IV)

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The Justice Department has repeated on several occasions that it intends to aggressively prosecute corporations for sanctions and export controls violations. The “New FCPA” is how the Justice Department characterizes its...more

The Volkov Law Group

John Deere Reaches $9.9 Million Settlement with SEC over FCPA Violations

The Volkov Law Group on

The U.S. Securities and Exchange Commission (“SEC”) recently instituted proceedings against Deere & Company (“John Deere”), a leading global manufacturer of agricultural and heavy machinery, for multiple violations of the...more

The Volkov Law Group

DOJ Issues New FCPA Declination: Boston Consulting Group Pays $14.4 Million

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The Justice Department is encouraging companies to voluntarily disclose criminal violations — “Come in and confess” and DOJ offers promises of a declination.  But even a declination comes with a requirement — the company has...more

Health Care Compliance Association (HCCA)

The private sector's role in fighting corruption

By Gerry Zack, CCEP, CFE, CIA Things are changing when it comes to anticorruption. The U.S. Foreign Extortion Prevention Act (FEPA)— passed in December 2023—makes demanding, seeking, receiving, accepting, or agreeing to...more

Thomas Fox - Compliance Evangelist

The Boston Consulting Group Declination: A Money Shot for Clawbacks

In a recent development that has garnered significant attention in the compliance community, the U.S. Department of Justice (DOJ) declined prosecution of Boston Consulting Group, Inc. (BCG) for violations of the Foreign...more

Thomas Fox - Compliance Evangelist

Compliance Lessons on Mergers and Acquisitions from Star Trek: The Ultimate Computer

Last month, I wrote a blog post on the tone at the top, exemplified in Star Trek’s Original Series episode, Devil in the Dark. Based on the response, some passionate Star Trek fans are out there. I decided to write a series...more

The Volkov Law Group

Tracking FCPA Individual Enforcement

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While FCPA enforcement against companies has been relatively quiet this year, despite a strong beginning to the year — the SAP case for $220 million; and the Gunvor case for $661 million — DOJ has been pushing a number of...more

Thomas Fox - Compliance Evangelist

Lessons on Ongoing Monitoring and Continuous Improvement from Star Trek: Spectre of the Gun

Last month, I wrote a blog post on the tone at the top, exemplified in Star Trek’s Original Series episode, Devil in the Dark. Based on the response, some passionate Star Trek fans are out there. I decided to write a series...more

Benesch

White Collar Quarterly Report - August 2024

Benesch on

In 2023, the number of federal corporate prosecutions remained far below the 25-year average after two consecutive years of increases. ..The DOJ’s Fraud Section secured just $690 million in penalties across eight...more

Thomas Fox - Compliance Evangelist

Lessons on Managing 3rd Parties from Star Trek: The Omega Glory

Last month, I wrote a blog post on the tone at the top, exemplified in Star Trek’s Original Series episode, Devil in the Dark. Based on the response, some passionate Star Trek fans are out there. I decided to write a series...more

Thomas Fox - Compliance Evangelist

Training and Communications Lessons from Star Trek: The Trouble with Tribbles

Last month, I wrote a blog post on the tone at the top, exemplified in Star Trek’s Original Series episode, Devil in the Dark. Based on the response, some passionate Star Trek fans are out there. I decided to write a series...more

Thomas Fox - Compliance Evangelist

Risk Assessment Lessons from Star Trek: Balance of Terror

Last month, I wrote a blog post on the tone at the top, exemplified in Star Trek’s Original Series episode, Devil in the Dark. Based on the response, some passionate Star Trek fans are out there. I decided to write a series...more

Thomas Fox - Compliance Evangelist

DOJ Whistleblower Pilot Program: Transforming the Compliance Landscape

In a world where corporate integrity and accountability are more crucial than ever, the Department of Justice (DOJ) ‘s Whistleblower Pilot Program announcement marks a pivotal moment for compliance professionals. This...more

Thomas Fox - Compliance Evangelist

The Foreign Corrupt Practices Handbook: Interview with the Authors

I recently spoke with the Foreign Corrupt Practices Act (FCPA) Handbook authors Robert Tarun and Peter Tomczak from Baker McKenzie for a two-part podcast episode. The depth of knowledge and experience in white-collar crime,...more

NAVEX

The Supreme Court Made Its Rulings; Corporate Compliance Needs March On

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At the end of June, the U.S. Supreme Court issued major decisions on the enforcement power of the Securities and Exchange Commission, what does or doesn’t qualify as a bribe of government officials, and on federal judges’...more

NAVEX

What a New SEC Enforcement Sweep Is Really Telling Us

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Attention all compliance officers at large technology companies – have you checked your mail lately? Because you might find a letter from the Securities and Exchange Commission with FCPA risk written all over it....more

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