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
Hosted by the C5 Group, the 18th Annual Conference on Anti-Corruption London will bring together the brightest minds in anti-corruption and compliance to review the most pressing multi-jurisdictional enforcement updates...more
Hosted by the American Conference Institute, the 19th Annual FCPA & Anti-Corruption Conference for the Life Sciences Industry returns for another exciting year with carefully researched programming based on critical findings...more
Global Capability Centers (GCCs) located in India continue to evolve from labor arbitrage and cost savings initiatives to innovation centers for digital transformation, supporting cloud, mobile, data security, data analytics,...more
There are many international and Asia-based investors looking to invest in companies in the US for both strategic and commercial reasons, and in return they offer attractive sources of funding. Often, financial investments...more
Eddie Van Halen died yesterday. He is the first rocker, more or less, of my generation to die after the age of 60. He was also one of the greatest guitarists ever. Indeed, I would rank him as the best guitarist of his...more
In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international anti-corruption developments from the past month, with links to primary...more
COVID-19 and IT service provider contracts: A checklist for force majeure events - The COVID-19 pandemic, and the various restrictions that have been implemented in response to it, are causing extraordinary business...more
Given the paucity of leadership coming out of Washington during this crisis, I thought it would be a ripe time to consider some innovations in compliance leadership. While many compliance departments may have begun more as a...more
Yesterday, I wrote about the Cardinal Health, Inc. Foreign Corrupt Practices Act (FCPA) resolution with the Securities and Exchange Commission (SEC). One of the areas that many compliance practitioners confuse is evaluating...more
I have been taking online classes this year from MasterClass, beginning with the writers. I have made it through James Patterson, Malcolm Gladwell and David Baldacci. It is a great way to hear from some of the top...more
Yesterday, I looked at some of the more creative bribery schemes identified in 2019 Foreign Corrupt Practices Act (FCPA) enforcement actions. They were schemes involving distributors, joint ventures (JVs) and fraudulent...more
In today’s blog post, I want to look at some of the more unusual bribery schemes from Foreign Corrupt Practices Act (FCPA) enforcement actions in 2019. Some of these schemes were not unusual but they were accomplished with...more
Whether they are Joint Ventures (JVs), partnerships, franchises, team agreements, strategic alliances or one of the myriad types of business relationships a U.S. company can form outside the U.S., they present diverse risks...more
When exploring a joint venture (JV) with a Chinese partner, it is important to consider the legal and cultural differences that may contribute to the success or delay of your project. Below are some common risks associated...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
The ongoing trade tensions between the U.S. and China have caused some U.S. companies to become increasingly concerned that the Chinese authorities may subject their local operations to closer scrutiny, leading these...more
Joint ventures pose a unique constellation of anti-corruption risks. Like third-party risks, companies that enter into joint ventures face significant anti-corruption risks, especially in those situations where a state-owned...more
• Companies that operate globally face substantial risks associated with activities funded by multilateral development banks (MDBs). • Several recent debarment actions by the World Bank highlight those risks. • To...more
Joint ventures provide many FCPA risks that other types of business relationships do not bring. For instance, the joint venture may interact with foreign government officials or employees of a state-owned enterprise; then...more
Just as the FCPA enforcement field is covered with actions centering around mergers and acquisitions, there are multiple actions involving joint ventures (JVs). JVs continue to plague many US companies up to this day. In many...more
I want to consider the impending opening of Cuba to US business, what you can do now and what you must wait for until the embargo is lifted; all from the perspective of compliance with the Foreign Corrupt Practices Act...more
Sometimes I get inspired when writing blog posts and sometimes I get on a roll. It is a bit of both this week and today, as previously this week, I have focused on Department of Justice (DOJ) pronouncements on their view of...more
The Och-Ziff settlement has now set the stage for the Justice Department and the SEC to focus its enforcement eye on the private equity and hedge fund industry. The Och-Ziff action was initiated in response to the SEC’s...more
On September 28, 2016, the SEC announced that Anheuser-Busch agreed to pay $6 million to settle charges of Foreign Corrupt Practices Act and Dodd-Frank whistleblower violations. The SEC’s order stated that AB InBev violated...more
Just in time for National Beveridge Day comes the Foreign Corrupt Practices Act (FCPA) enforcement action involving Anheuser-Busch InBev (ABI), where the company paid $6 million to settle charges that it violated the FCPA and...more