Wicked Coin: FIFA: Soccer, Scandal, and Sportswashing
Episode 339: Four Sanctions Cases Everyone Should Know
Episode 338 -- Deep Dive into the Deere SEC FCPA Case
FCPA Survival Guide - Step 8 - Investing in Compliance
Episode 328 -- Sanctions Enforcement Risks and Redlines
FCPA Survival Guide: Step 3 - Extensive Remediation
Episode 324 -- Third-Party Risks and Sanctions Compliance
Compliance Tip of the Day – Compliance Lessons from the Albemarle FCPA Enforcement Action
FCPA Survival Guide: Step 1 - Self-Disclosure
All Things Investigations: Compliance Lessons from Gunvor and Trafigura Enforcement Actions
Corruption, Crime & Compliance: Deep Dive into The Trafigura FCPA Settlement
Episode 317 -- A Deep Dive into the Trafigura FCPA Settlement
What's Going on with FCPA?
Episode 316 -- DOJ Announces New Whistleblower Policy
Compliance into The Weeds: Trafigura FCPA Enforcement Action
Corruption, Crime & Compliance: Deep Dive into The Gunvor FCPA Settlement
Episode 314 -- A Deep Dive into Gunvor's FCPA Settlement
Corruption, Crime & Compliance: DOJ’s Shifting Approach to Recidivism and Self-Disclosure
Episode 311 -- Tom Fox on FCPA Enforcement: Self Disclosure and Recidivism
Episode 307 -- Sanctions Enforcement Review and Predictions for 2024
Due diligence is generally recognized in three levels: Level I, Level II and Level III. Each level is appropriate for a different level of corruption risk. The key is to develop a mechanism to determine the appropriate level...more
Federal prosecutors enjoy flipping through the United States Criminal Code, 18 U.S.C. §§ 1 et seq., to pick out tools to charge defendants. Over the last ten years, DOJ’s reliance on criminal charges in FCPA cases has...more
On June 3, 2021, the White House issued a memorandum formally establishing the fight against corruption as a core national security interest. The memorandum directed the development of a presidential strategy to, among other...more
The new United States Strategy on Countering Corruption includes several important statements of interest to legal and compliance professionals. ...more
Last week, the Biden Administration unveiled a sweeping “whole-of-government approach” to combating corruption. Identifying corruption as a “cancer within the body of societies—a disease that eats at the public trust and the...more
On May 25, 2021, the U.S. Department of Justice (“DOJ”) unsealed an indictment charging two Austrian citizens, Peter Weinzierl (“Weinzierl”) and Alexander Waldstein (“Waldstein”), for their roles in a scheme to launder...more
Blog after blog, commentator after commentator, and everyone else who has an opinion has been repeating the same message – the Biden Administration is going to increase enforcement risks....more
Existe una propuesta de valor presentable a un cliente cuando un abogado trabaja en conjunto con un contador forense. Los litigios a menudo implican la superposición de múltiples y complejos asuntos legales y contables....more
There is a value added for a client when an Attorney is working in tandem with a forensic accountant. Litigation often involves overlapping complex accounting and legal issues. Working together, Attorneys and Forensic...more
In case it was not already clear, the U.S. Department of Justice recently confirmed that ensuring the use of cryptocurrency “is safe, and does not imperil our public safety or our national security, is vitally important to...more
There are other U.S laws that intersect with the FCPA. A violation of the FCPA may also constitute a violation of the characteristics of another U.S. Law – in this case the Travel Act....more
The Covid-19 Pandemic and the accompanying reduction in economic activity has been a rationale for Financial Institutions (FI) to re-analyze their budgets for compliance training and education. FIs, as well as businesses in...more
Addressing the Evolving Risks - Warren Buffett said that “only when the tide goes out do you discover who’s been swimming naked.” Buffett was not talking about compliance programs in a time of crisis, but his wisdom applies...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
Yesterday, the Department of Justice (DOJ) announced three charges against Jose Carlos Grubisich, the former Chief Executive Officer (CEO) of Braskem S.A. (Braskem), a publicly traded Brazilian petrochemical company, for his...more
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
Over the past few blog posts, I have been exploring a recent article in Harvard Business Review (HBR) by Gary P. Pisano, entitled “The Hard Truth About Innovative Cultures”....more
This issue of Skadden’s semiannual Cross-Border Investigations Update takes a close look at recent cases, regulatory activity and other key developments, including DOJ guidance on the use of corporate monitors in criminal...more
Last year, a group of U.S. military veterans and the relatives of troops killed in Iraq filed a lawsuit against several large international pharmaceuticals, accusing them of aiding and abetting terrorism by selling products...more
In the current environment of increased regulation, transparency, reporting and heightened compliance standards, the US and its Government Agencies have an arsenal of tools with extraterritorial application. ...more
On January 19, 2017, the Western Union Company (“Western Union” or the “Company”) entered into a deferred prosecution agreement (“DPA”) with the Department of Justice (“DOJ”), in which Western Union admitted to willful...more
I recently read an article in the MIT Sloan Management Review, entitled “How Blockchain Will Change Organizations”, where authors Don Tapscott and Alex Tapscott speculate that the transformations which blockchain may...more
After a conventional presidential campaign, determining the policy priorities and direction of the incoming administration with respect to the Justice Department’s white collar law enforcement responsibilities can be a...more
Yesterday I presented my views on why I believe that Foreign Corrupt Practices Act (FCPA) enforcement will continue under the new administration. Today, I want to begin a multi-part series (sorry I don’t know how long it will...more