News & Analysis as of

Foreign Corrupt Practices Act (FCPA) Self-Disclosure Requirements Bribery

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for August 2024

Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption law and enforcement developments from the past...more

American Conference Institute (ACI)

The DOJ’s New Pilot Programs: A Bane for Compliance Programs

For years, Department of Justice officials have stressed how important chief compliance officers are as the first line of defense in fighting corporate crimes. While that’s true, compliance programs now have a competitor in...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for April 2024

Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption law and enforcement developments from the past...more

Thomas Fox - Compliance Evangelist

The SAP FCPA Enforcement Action-Part 4: The Fines: Self-Disclose, Self-Disclose, Self-Disclose

We continue our exploration of the SAP Foreign Corrupt Practices Act (FCPA) enforcement action. Today we go full geek in a look at the fine and penalty and most importantly what the fine and penalty communicate about what the...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for November 2023

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Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption law and enforcement developments from the past...more

Cozen O'Connor

DOJ Signals Increased Emphasis on Data Analytics to Prosecute FCPA Global Corruption

Cozen O'Connor on

On November 29, 2023, Department of Justice (DOJ or Department) policymakers announced explicitly that they are, for the first time, leveraging data analytics to help proactively identify and prosecute crimes in foreign...more

Morrison & Foerster LLP

Top 10 Anti-Corruption Developments for October 2023

Morrison & Foerster LLP on

Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption law and enforcement developments from the past...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for February 2023

Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption law and enforcement developments from the past...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for January 2023

Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption law and enforcement developments from the past...more

Latham & Watkins LLP

DOJ’s Updated Corporate Enforcement Policy Aims to Incentivize Compliance

Latham & Watkins LLP on

Companies that self-disclose, cooperate, and remediate could benefit from significantly reduced fines and possible declinations even in cases with aggravating factors. In a speech at Georgetown University Law Center on...more

Thomas Fox - Compliance Evangelist

The Herbalife FCPA Enforcement Action: Part 4 – Final Thoughts

We are the end of my multi-part exploration of the Herbalife Nutrition Ltd (Herbalife) Foreign Corrupt Practices Act (FCPA) enforcement action with both the Department of Justice (DOJ) and Securities and Exchange Commission...more

BakerHostetler

DOJ and SEC Publish New FCPA Resource Guide

BakerHostetler on

On the eve of the July 4th holiday, the Criminal Division of the Department of Justice (the “DOJ”) and the Enforcement Division of the Securities and Exchange Commission (the “SEC”) quietly published the second edition of the...more

K&L Gates LLP

DOJ and SEC Issue First Major Update to FCPA Resource Guide Since 2012: What You Need to Know

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INTRODUCTION - On 3 July 2020, the U.S. Department of Justice (DOJ) and the U.S. Securities and Exchange Commission (SEC) released the second edition of the Resource Guide to the U.S. Foreign Corrupt Practices Act (Resource...more

Thomas Fox - Compliance Evangelist

The FCPA Resources Guide, Second Edition – FCPA Corporate Enforcement Policy

Obviously, there have been multiple developments by the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) since 2012 release of the First Edition of the FCPA Resources Guide (2012 Resources Guide). The...more

Hogan Lovells

ADG Insights: Bribery and corruption continues to be a risk for ADG companies - February 2020

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The anti-corruption and bribery enforcement landscape is constantly evolving. Companies operating in the Aerospace, Defense, and Government Services (ADG) industry sector must therefore vigilantly track developments in this...more

Thomas Fox - Compliance Evangelist

Billion Dollar Baby: Ericsson FCPA Enforcement Action – Part 1: Introduction

Last week the Justice Department (DOJ) announced a resolution of the long stand Foreign Corrupt Practices Act (FCPA) enforcement action involving Telefonaktiebolaget LM Ericsson (Ericsson), a multinational networking and...more

Thomas Fox - Compliance Evangelist

Ericsson Resolves Billion Dollar FCPA Enforcement Action

In an anticipated settlement, the Justice Department announced a settlement of a massive, multi-decades long, multiple country corruption scheme with the Swedish telecom entity, Telefonaktiebolaget LM Ericsson (Ericsson). The...more

The Volkov Law Group

DOJ Tweaks FCPA Corporate Enforcement Policy

The Volkov Law Group on

The Department of Justice recently announced updates to its Foreign Corrupt Practices Act Corporate Enforcement Policy. While the changes were relatively minor, the modifications underscored important principles surrounding...more

Foodman CPAs & Advisors

Did you know that there is FCPA Individual Compliance Responsibility?

Foodman CPAs & Advisors on

The Foreign Corrupt Practices Act (FCPA) prohibits payment of bribes to foreign officials to assist with obtaining or retaining business.  It also requires companies whose securities are listed in the US to make and keep...more

Thomas Fox - Compliance Evangelist

Brighton Rock and the UTC FCPA Enforcement Action

According to Harry Cassin, writing in the FCPA Blog, “In late 2013 and early 2014, United Technologies self-disclosed to the DOJ, SEC, and the SFO the status of an internal investigation regarding a non-employee sales rep for...more

Holland & Knight LLP

DOJ Makes Permanent Its Program to Incentivize Self-Disclosure in FCPA Investigations

Holland & Knight LLP on

• The U.S. Department of Justice's (DOJ) pilot program established in 2016 to incentivize companies to self-report violations of the Foreign Corrupt Practices Act (FCPA) will, with slight revisions, be made permanent. •...more

Hogan Lovells

Why Healthcare and Life Sciences Companies Need to Step Up Their Compliance Efforts in Advance of a U.S. Government Investigation

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In this hoganlovells.com interview, Hogan Lovells partner Gejaa Gobena discusses how the perception of compliance, remediation, and self-disclosure has evolved in the eyes of government prosecutors from how they factor at...more

Ruder Ware

Sally Yates’ was Already Famous for Changing the Focus of Compliance Investigations - The Yates Memorandum

Ruder Ware on

By now the whole world knows about Sally Yates. We are likely to see a lot more of her as a central figure in Congressional investigations. For some of us who deal with compliance investigations, Sally Yates was famous long...more

Morgan Lewis

DOJ Announces Extension of FCPA Pilot Program

Morgan Lewis on

The US Department of Justice plans to extend its FCPA Pilot Program, an initiative developed to encourage companies to self-report bribery violations and provide extensive cooperation in exchange for reduced penalties,...more

Thomas Fox - Compliance Evangelist

When Leslie Caldwell Talks FCPA, You Should Listen

November begins the final push for the compliance conference season, which customarily ends with the ACI National FCPA Conference. During November and into early December, Department of Justice (DOJ) officials have...more

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