As the interplay between export controls, trade sanctions, and anticorruption enforcement continues to intensify, multinational companies must remain vigilant in ensuring that their compliance programs address the many...more
9/25/2024
/ Anti-Corruption ,
Boycotts ,
Bureau of Industry and Security (BIS) ,
Compliance ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement ,
Export Administration Regulations (EAR) ,
Export Controls ,
FinCEN ,
Foreign Corrupt Practices Act (FCPA) ,
Fraud ,
Multinationals ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Penalties ,
Popular ,
Russia ,
Sanction Violations ,
Self-Disclosure Requirements ,
Supply Chain ,
Ukraine ,
Voluntary Disclosure
In December 2023, President Joe Biden signed the Foreign Extortion Prevention Act (FEPA) into law under the broader Fiscal Year 2024 National Defense Authorization Act (NDAA). While FEPA’s sponsors hailed it as “the most...more
3/1/2024
/ Anti-Bribery ,
Anti-Corruption ,
Bribery ,
Chief Compliance Officers ,
Compliance ,
Cooperation ,
Department of Justice (DOJ) ,
FEPA ,
Foreign Corrupt Practices Act (FCPA) ,
Fraud ,
Investigations ,
Jurisdiction ,
NDAA
Juggling conversations with multiple enforcement agencies simultaneously in the course of a cross-border anticorruption investigation can be a difficult and daunting task for legal and compliance teams. Getting it right can...more
4/18/2023
/ Anti-Corruption ,
Compliance ,
Cross-Border ,
Department of Labor (DOL) ,
Enforcement Authority ,
EU ,
Financial Conduct Authority (FCA) ,
Foreign Corrupt Practices Act (FCPA) ,
Fraud ,
General Data Protection Regulation (GDPR) ,
Investigations ,
UK
For life sciences companies, Brazil’s market offers both an abundance of business opportunities and a myriad of on-the-ground regulatory compliance challenges for new entrants. Getting the market-entry strategy right will...more
3/16/2023
/ Anti-Corruption ,
Brazil ,
Business Opportunities ,
Compliance ,
Coronavirus/COVID-19 ,
Foreign Corporations ,
Healthcare ,
International Trade ,
Licensing Rules ,
Life Sciences ,
New Regulations ,
Permits ,
Pharmaceutical Industry ,
Telemedicine
For more than two years now, heads of the U.S. Department of Justice have maintained a steady drumbeat that they expect companies today to have in place a sound data analytics compliance program to proactively mitigate risks....more
3/2/2023
/ Analytics ,
Anti-Corruption ,
Artificial Intelligence ,
CFTC ,
Compliance ,
Corporate Crimes ,
Corporate Misconduct ,
Data Collection ,
Department of Justice (DOJ) ,
Enforcement ,
Ethics ,
Foreign Corrupt Practices Act (FCPA) ,
Machine Learning ,
Risk Mitigation ,
Securities and Exchange Commission (SEC)
In recent years, U.S. enforcement agencies have signaled that a data-analytics driven compliance program is more than a nice to have, it’s a must-have if companies are going to get more adept at demonstrating the...more
Officials with the U.S. Department of Justice have portended a sea change in the oversight responsibilities of chief compliance officers (CCOs) as it concerns corporate resolutions going forward.
In public remarks made March...more
8/9/2022
/ Anti-Corruption ,
CEOs ,
Certification Requirements ,
Chief Compliance Officers ,
Compliance ,
Criminal Liability ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Guilty Pleas ,
Internal Controls ,
Non-Prosecution Agreements ,
Personal Liability
In line with the Biden administration’s declaration last year that anticorruption is a “core United States national security interest,” sanctions evasion enforcement rapidly has become a core priority for the Department of...more
7/12/2022
/ Anti-Corruption ,
Best Practices ,
Compliance ,
Corporate Crimes ,
Cross-Border Transactions ,
Cyber Crimes ,
Department of Justice (DOJ) ,
Due Diligence ,
Economic Sanctions ,
Enforcement Actions ,
Financial Institutions ,
FinCEN ,
Foreign Corrupt Practices Act (FCPA) ,
Money Laundering ,
Multinationals ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Sanction Violations ,
Terrorist Financing ,
U.S. Treasury