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
12/17/2016
/ Anti-Corruption ,
Bribery ,
China ,
Compliance ,
Corporate Counsel ,
Department of Justice (DOJ) ,
Federal Pilot Programs ,
Financial Services Industry ,
Foreign Corrupt Practices Act (FCPA) ,
France ,
Presidential Elections ,
Securities and Exchange Commission (SEC) ,
Trump Administration ,
Whistleblowers
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
11/17/2016
/ Aircraft ,
Anti-Bribery ,
Anti-Corruption ,
Brazil ,
China ,
Compliance ,
Corruption ,
Department of Justice (DOJ) ,
Foreign Corrupt Practices Act (FCPA) ,
Ireland ,
Latin America ,
OECD ,
Pharmaceutical Industry ,
Retaliation ,
Russia ,
Securities and Exchange Commission (SEC) ,
Spain ,
Switzerland ,
UK ,
Venezuela ,
Whistleblowers
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
10/28/2016
/ Africa ,
Anti-Corruption ,
Brazil ,
China ,
Corporate Counsel ,
Cosmetics ,
Department of Justice (DOJ) ,
Disgorgement ,
Foreign Corrupt Practices Act (FCPA) ,
Hedge Funds ,
India ,
Pharmaceutical Industry ,
Russia ,
Securities and Exchange Commission (SEC) ,
UK
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
9/20/2016
/ Administrative Law Judge (ALJ) ,
Anti-Corruption ,
Austria ,
Brazil ,
Bribery ,
China ,
Civil Monetary Penalty ,
Class Action ,
Compliance ,
Corporate Counsel ,
Disgorgement ,
Federal Contractors ,
Foreign Corrupt Practices Act (FCPA) ,
Health Care Providers ,
Hedge Funds ,
Petrobras ,
Pharmaceutical Industry ,
Popular ,
Public Procurement Policies ,
Russia ,
Securities and Exchange Commission (SEC) ,
Severance Agreements ,
Ukraine ,
Whistleblowers
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
8/30/2016
/ Airlines ,
Alstom ,
Anti-Corruption ,
Argentina ,
Brazil ,
Bribery ,
China ,
Civil Forfeiture ,
Compliance ,
Criminal Prosecution ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Fiduciary Duty ,
Foreign Corrupt Practices Act (FCPA) ,
Forfeiture ,
Malaysia ,
Mexico ,
Misappropriation ,
Offshore Drilling ,
Section 7 of UKBA ,
Securities and Exchange Commission (SEC) ,
Serious Fraud Office (SFO) ,
Singapore ,
Sovereign Wealth Funds ,
Subsidiaries ,
UK
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
7/29/2016
/ Administrative Proceedings ,
Anti-Corruption ,
Brazil ,
Breach of Contract ,
Bribery ,
China ,
Constitutional Challenges ,
Corporate Counsel ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Federal Pilot Programs ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Subsidiaries ,
Guilty Pleas ,
Internet Service Providers (ISPs) ,
Japan ,
McDonnell v US ,
Medical Devices ,
Mexico ,
Non-Prosecution Agreements ,
OECD ,
Pharmaceutical Industry ,
Russia ,
SCOTUS ,
Securities and Exchange Commission (SEC) ,
Serious Fraud Office (SFO) ,
UK ,
Venezuela ,
Yates Memorandum
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
6/28/2016
/ Anti-Corruption ,
Brazil ,
Bribery ,
Convictions ,
Corporate Counsel ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Disgorgement ,
Foreign Corrupt Practices Act (FCPA) ,
IRS ,
Scandals ,
Securities and Exchange Commission (SEC) ,
Serious Fraud Office (SFO) ,
Tax Deductions ,
Transparency ,
UK
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
5/12/2016
/ Anti-Corruption ,
Bribery ,
Canada ,
Casinos ,
China ,
Compliance ,
Corporate Counsel ,
Criminal Prosecution ,
Deferred Prosecution Agreements ,
Foreign Corrupt Practices Act (FCPA) ,
Kickbacks ,
Panama Papers ,
Real Estate Investments ,
Securities Fraud ,
Self-Reporting ,
UK ,
UK Bribery Act ,
US v Yates ,
Venezuela ,
Young Lawyers
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
4/25/2016
/ Anti-Corruption ,
China ,
Compliance ,
Corporate Counsel ,
Department of Justice (DOJ) ,
EU ,
Foreign Corrupt Practices Act (FCPA) ,
Popular ,
Securities and Exchange Commission (SEC) ,
UK ,
Young Lawyers
On April 5, 2016, Assistant Attorney General Leslie Caldwell, who heads the Criminal Division of the U.S. Department of Justice, announced a new “FCPA pilot program” designed to motivate companies to voluntarily self-disclose...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 in the past month, with links to primary...more
2/19/2016
/ Anti-Corruption ,
Bribery ,
Compliance ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Foreign Corrupt Practices Act (FCPA) ,
Governor McDonnell ,
Kickbacks ,
Money Laundering ,
OECD ,
Petrobras ,
Qualcomm ,
SCOTUS ,
Serious Fraud Office (SFO) ,
Spain ,
Transparency
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 in the past month, with links to primary...more
1/15/2016
/ Anti-Corruption ,
Brazil ,
Bribery ,
China ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Foreign Corrupt Practices Act (FCPA) ,
Indictments ,
Panama ,
Petrobras ,
Serious Fraud Office (SFO) ,
UK ,
Venezuela
On Aug. 12, 2015, Vincente Garcia (former head of Latin American sales for SAP International Inc.) pled guilty in federal court in San Francisco to violations of the Foreign Corrupt Practices Act. In addition to pleading...more
8/28/2015
/ Anti-Bribery ,
Bribery ,
Chief Compliance Officers ,
Compliance ,
Criminal Conspiracy ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Federal Contractors ,
Foreign Corrupt Practices Act (FCPA) ,
Government Officials ,
Kickbacks ,
Panama ,
Popular ,
Securities and Exchange Commission (SEC) ,
Software ,
Technology Sector
On August 12, 2015, Vincente Garcia (former head of Latin American sales for SAP International, Inc.) pleaded guilty in federal court in San Francisco to violations of the Foreign Corrupt Practices Act (FCPA). In addition to...more
8/18/2015
/ Anti-Bribery ,
Bribery ,
Criminal Conspiracy ,
Department of Justice (DOJ) ,
Federal Contractors ,
Foreign Corrupt Practices Act (FCPA) ,
Fraud ,
Guilty Pleas ,
Popular ,
Securities and Exchange Commission (SEC) ,
Subsidiaries
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 in the past month with links to primary...more
Following on the heels of its landmark 2014 ruling in United States v. Esquenazi, the Eleventh Circuit has issued another important decision addressing the Foreign Corrupt Practices Act (FCPA) in a related case, United States...more
The U.S. Department of Justice just issued its most recent Foreign Corrupt Practices Act opinion release, only the second in 2014. The requestor, a publicly traded U.S. consumer products company, sought an opinion as to...more
The Department of Justice (“DOJ” or the “Department”) just issued its most recent FCPA Opinion Release, only the second in 2014. The Requestor, a publicly traded U.S. consumer products company, sought an opinion as to whether...more
11/20/2014
/ Department of Justice (DOJ) ,
Due Diligence ,
Enforcement Actions ,
FCPA Guidance ,
Foreign Corrupt Practices Act (FCPA) ,
Halliburton ,
Halliburton v Erica P. John Fund ,
Integration ,
Jurisdiction ,
Successor Liability ,
Target Company
In This Issue:
- Recent Trends in FCPA Enforcement – First Half of 2014
- Ukraine/Russia–Related Sanctions
- New Executive Order Places Additional Reporting Obligations on Government Contractors and...more
10/14/2014
/ China ,
Emerging Technology Companies ,
Enforcement Actions ,
Federal Contractors ,
Foreign Corrupt Practices Act (FCPA) ,
Reporting Requirements ,
Russia ,
Sanctions ,
Suspensions & Debarments ,
Ukraine ,
World Bank
Charles Duross is the head of Morrison & Foerster’s Global Anti-Corruption Practice. He is the former head of the Department of Justice’s Foreign Corrupt Practices Act unit, where he took a leading role in developing and...more
While many people don’t know it, a bribery scandal in Japan in 1976 was part of the motivation for the Foreign Corrupt Practices Act (FCPA), which was signed into law on December 19, 1977. Almost exactly two decades later,...more
Federal appellate court decisions interpreting the Foreign Corrupt Practices Act (FCPA) are rare. Very rare. Indeed, in the statute’s 36-year history there have been barely more than a handful of appellate court decisions...more
What matters were you particularly proud to have been involved in during your time at the DoJ?
I’m proud of all of it but I think there are probably a couple of specific matters that stand out in my mind. The first...more