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Recent Sanctions Enforcement Actions Demonstrate Importance of  Incorporating All Available Data into Screening

For U.S. businesses, sanctions compliance has never been more challenging or more important. The U.S. has responded to Russia’s invasion of Ukraine with a broad range of sanctions targeting the Russian government, its...more

Brazilian Airline to Pay Millions in Coordinated Foreign Bribery Resolution

On September 15, 2022, GOL Linhas Aéreas Inteligentes S.A. (GOL), Brazil’s second largest domestic airline, resolved long-running parallel investigations by the U.S. Department of Justice (DOJ) and the Securities and Exchange...more

The Perils of Global Expansion: World’s Largest Ad Agency Sanctioned $19 Million for FCPA Violations, Insufficient Controls

Global expansion without adequate controls is asking for trouble. That’s the lesson of a $19 million settlement between WPP, the world’s largest advertising agency, and the U.S. Securities and Exchange Commission (SEC) to...more

Second Circuit Clarifies Limits of FCPA’s Extraterritorial Reach

The U.S. Court of Appeals for the Second Circuit narrowed the reach of the Foreign Corrupt Practices Act (“FCPA” or “the Act”) in ruling that the government cannot use aiding and abetting or conspiracy statutes to charge a...more

Anti-Corruption Enforcement in Brazil is in High Gear

Headlines of Brazil’s push to fight corruption are everywhere. The Petrobras scandal involves contracts worth billions of dollars, and prosecutors have uncovered a U.S. connection. The public is outraged and has called for...more

China’s Focus on Combatting Commercial Bribery Is a Wake-Up Call

Earlier this month, six former employees of Tencent Holdings (Tencent), including Liu Chunning, a now high-level executive of Alibaba Group, were detained by Chinese authorities as part of a bribery investigation relating to...more

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