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
In December 2023, US Congress passed a landmark anti-bribery law: the Foreign Extortion Prevention Act (FEPA). FEPA was designed to supplement the Foreign Corrupt Practices Act (FCPA) and expand liability to foreign...more
Much has been said about the Foreign Extortion Prevention Act (“FEPA”) that President Biden signed into the law in December 2023, with particular attention given to the corrupt foreign officials who seek bribes from...more
The breadth of the recently enacted FEPA presents pitfalls for U.S. companies dealing with foreign governments and state-owned entities requiring significant caution and effective compliance controls....more
You can always learn a lot from reviewing the underlying conduct to an FCPA enforcement action. Chief compliance officers can identify specific risk factors, mitigation steps and root causes for bribery schemes. ...more
Even with the absence of any major DOJ FCPA enforcement actions, DOJ issued an interesting FCPA Opinion Letter last week addressing application of the FCPA in circumstances where organizations face imminent serious bodily...more
This is the second post in this year’s series examining important trends and new development in white collar law and investigations. Our previous post discussed health care enforcement. Up next: trends in tax enforcement. ...more
A. Basic Overview of Statute - The Foreign Corrupt Practices Act of 1977, as amended, 15 U.S.C. §§ 78dd-1, et seq. (FCPA), makes it unlawful for U.S. persons and entities and others who act within the jurisdiction of the...more
On August 14, 2020, the Department of Justice (DOJ) issued its first Foreign Corrupt Practices Act (FCPA) Opinion Procedure Release in six years. In the opinion, DOJ advised that it would not bring an enforcement action...more
For the remainder of the week, we return to Sherlock Holmes-themed blog posts. We have finished our review of The Adventures of Sherlock Holmes and now move on to The Memoirs of Sherlock Holmes. We begin this week’s adventure...more
On July 3, 2020, the Department of Justice (“DOJ”) and Securities and Exchange Commission (“SEC”) updated their 2012 joint guidance on the Foreign Corrupt Practices Act (“FCPA”) in the SEC and DOJ’s FCPA Resource Guide...more
On June 4, 2018, Société Générale S.A., together with a subsidiary of the Paris-based global financial services institution, announced an agreement with both French and American authorities to resolve charges relating to...more
Seyfarth Synopsis: No differently than companies doing business overseas—especially in high-risk markets—American colleges and universities who do business overseas face real risks of violating the Foreign Corrupt Practices...more
New rules issued by the U.S. Securities and Exchange Commission (SEC) that require resource extraction issuers to disclose payments made to U.S. and foreign governments for the commercial development of oil, natural gas or...more