News & Analysis as of

Foreign Corrupt Practices Act (FCPA) Recordkeeping Requirements

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

Adams and Reese LLP

Beyond Borders: Navigating Global Business Compliance with the FCPA

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On March 7th, the Department of Justice (DOJ) announced a new whistleblower reward program intended to help prosecutors bring more foreign corruption cases. Under the new program, individuals who report corporate misconduct...more

Foley & Lardner LLP

What Every Multinational Company Should Know About … Anticorruption Red Flags (Part I)

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We have received several requests to publish a list of red flags pertinent to multinational organizations. To accommodate these requests, we are publishing a three-part series on anticorruption, export controls and economic...more

Fisher Phillips

Workplace Law Forecast 2024 - Your workplace law recap for 2023 and predictions for 2024 to help you prepare for the coming year.

Fisher Phillips on

When I reflect on the relationship that our firm has with our clients, I’m most proud of the fact that you can always count on us. That often means defending complex litigation, steering you through regulatory threats,...more

Davis Wright Tremaine LLP

Broker Dealer Regulatory Digest - August 2023

The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency, specifically focusing on:...more

Reveal

Information Governance 101: Everything You Need to Know To Get Started in 2023

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Information governance (IG) plays an increasingly significant role of the way corporations do business. But what do organizations do with all their data? Where do they store it—and is it secure, well organized, and...more

Guidepost Solutions LLC

Mergers + Acquisitions: 5 Tips For Navigating FCPA Risks

Among the risks inherent in a merger or an acquisition, few bring the financial and reputational consequences of the U.S. Foreign Corrupt Practices Act (“FCPA”). Background - The FCPA prohibits the offer, promise,...more

Foley Hoag LLP - White Collar Law &...

Companies Should Beware of Employees Texting Business Communications

Text messaging is convenient.  It is an informal and instant mode of communication now available through numerous apps, which allow an individual to use their synced phone, tablet, and computer to quickly fire off messages. ...more

Paul Hastings LLP

Ephemeral Messaging at the Office: Avoiding Pitfalls and Establishing Best Practices

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Users of ephemeral messaging applications may intend that their messages be—as the word “ephemeral” suggests—short lived, but the real-world consequences and legal ramifications from improper use of such apps can be anything...more

Pillsbury - Global Trade & Sanctions Law

Heightened Risks and Plenty of Pitfalls: Avoiding Corruption during COVID-19

Over the past nine months, companies and governments have competed goods and materials amidst scarcity and disrupted supply chains.  At the same time, governments, central banks, international organizations and NGOs have...more

Thomas Fox - Compliance Evangelist

The Problems with Facilitation Payments

The original version of the FCPA, enacted in 1977, contained an exception for payments made to non-U.S. officials who performed duties that were “essentially ministerial or clerical”. In 1988 Congress responded by amending...more

Locke Lord LLP

The Foreign Corrupt Practices Act

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FCPA AT A GLANCE - The Foreign Corrupt Practices Act of 1977 (the “FCPA”) was enacted in the wake of Securities & Exchange Commission (“SEC”) investigations in the mid-1970’s during which hundreds of U.S. companies...more

Sheppard Mullin Richter & Hampton LLP

Ninth Circuit Holds That Statutes Do Not Constitute “Rules or Regulations of the SEC” for Purposes of Sarbanes-Oxley Act...

In Wadler v. Bio-Rad Laboratories, Inc., No. 17-16193, 2019 WL 924827 (9th Cir. Feb. 26, 2019), the United States Court of Appeals for the Ninth Circuit held that statutes, including the Foreign Corrupt Practices Act...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - September 2018

ANTICORRUPTION DEVELOPMENTS - Petrobras Settles with U.S. Authorities Over Alleged FCPA Violations - On September 27, 2018, the U.S. Department of Justice (DOJ) and the Securities and Exchange Commission (SEC)...more

Blank Rome LLP

White Collar Watch (April 2018 - No. 1)

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Welcome to the spring edition of our White Collar Watch. Hopefully by the time you are reading this, winter’s storms (finally?) are behind us. 2018 has gotten off to a busy start for our practice and attorneys. We look...more

Foley & Lardner LLP

DOJ Issues New FCPA Policy Offering Incentives to Encourage Disclosure of Foreign Bribery and Corruption Misconduct

Foley & Lardner LLP on

On November 29, 2017, Deputy Attorney General Rod Rosenstein announced that the U.S. Department of Justice (DOJ) was issuing a new enforcement policy covering its enforcement of the Foreign Corrupt Practices Act (FCPA). The...more

The Volkov Law Group

Make Sure You Address Compliance with Export Controls

The Volkov Law Group on

Compliance officers have to avoid professional myopia. The focus of compliance these days has been on anti-corruption, antitrust, and AML, depending on your company’s industry. They fit nicely together under an...more

Dechert LLP

FCPA Enforcement Action Highlights Risks for the Financial Services Industry and Individual Executives

Dechert LLP on

New York-based hedge fund Och-Ziff Capital Management Group (the “Hedge Fund”) agreed to pay approximately $412 million to resolve charges brought by the U.S. Securities and Exchange Commission (“SEC”) and Department of...more

Manatt, Phelps & Phillips, LLP

Health Update - September 2015

Latest Healthcare False Claims Act Roundup and Top 3 Best Practices to Reduce Exposure - As the legal landscape in healthcare becomes increasingly complex, healthcare companies that receive federal program funds face...more

Katten Muchin Rosenman LLP

Bridging the Week - August 2015 #4

CME Group Files Disciplinary Actions for Trading Ahead of Block Trades and Failure to Supervise an Employee Engaging in Disruptive Trading Activities - In two cases of first impression, CME Group exchanges brought and...more

Locke Lord LLP

The Foreign Corrupt Practices Act: At a Glance

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In this issue: - FCPA AT A GLANCE - THE ANTI-BRIBERY PROVISIONS OF THE FCPA - TO WHOM THE ANTI-BRIBERY PROVISIONS APPLY - THE PAYMENT ELEMENT - THE CORRUPT INTENT ELEMENT - WHO IS A...more

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