Publicly announced Foreign Corrupt Practices Act (FCPA) enforcement activity in 2023 did not return to the levels seen a few years ago, as indicated by both the total number of cases against corporate and individual...more
1/31/2024
/ Acquisitions ,
Anti-Bribery ,
Anti-Corruption ,
Clawbacks ,
Compliance ,
Cooperation ,
Data Protection ,
Department of Justice (DOJ) ,
Enforcement ,
Enforcement Actions ,
Enforcement Guidance ,
Enforcement Priorities ,
Enforcement Statistics ,
Executive Compensation ,
FCPA Corporate Enforcement Policy (CEP) ,
FEPA ,
Foreign Corrupt Practices Act (FCPA) ,
Latin America ,
Mergers ,
Pilot Programs ,
Safe Harbors ,
Securities and Exchange Commission (SEC) ,
Self-Reporting ,
Voluntary Disclosure
On December 14, 2023, the U.S. Congress (Congress) passed the Foreign Extortion Prevention Act (FEPA), as a part of the Fiscal Year 2024 National Defense Authorization Act. The FEPA, which received bipartisan support, makes...more
While Foreign Corrupt Practices Act (FCPA) enforcement activity has not come close to returning to the heights seen a few years ago, 2022 reflected significant increases from the prior year in both the number of cases against...more
2/10/2023
/ Anti-Bribery ,
Anti-Corruption ,
Bribery ,
CFTC ,
Compliance ,
Cooperation ,
Corporate Crimes ,
Corporate Criminal Fines ,
Corruption ,
Cross-Border ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Enforcement Priorities ,
Enforcement Statistics ,
Foreign Corrupt Practices Act (FCPA) ,
Securities and Exchange Commission (SEC) ,
White Collar Crimes
On August 12, 2022, the US Court of Appeals for the Second Circuit issued another decision in a long-running criminal action that holds significant implications for the reach of the US Foreign Corrupt Practices Act (FCPA)...more
8/31/2022
/ Agents ,
Alstom ,
Anti-Bribery ,
Bribery ,
Compliance ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Authority ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Nationals ,
Securities and Exchange Commission (SEC) ,
Subsidiaries
Enforcement activity reached new heights in 2019. The year saw the two largest corporate resolutions in the history of the FCPA, corporate penalties paid to US enforcement agencies topped last year’s record levels, and...more
1/30/2020
/ Adoption ,
Anti-Bribery ,
Anti-Corruption ,
Arbitration ,
CFTC ,
Chief Compliance Officers ,
Civil Forfeiture ,
Compliance ,
Cooperation ,
Corporate Counsel ,
Corporate Governance ,
Criminal Conspiracy ,
Declination ,
Department of Justice (DOJ) ,
Enforcement ,
Enforcement Actions ,
Ericsson ,
Foreign Corrupt Practices Act (FCPA) ,
Government Investigations ,
Legislative Agendas ,
New Legislation ,
Pending Litigation ,
Personal Liability ,
Popular ,
Resource Extraction ,
Restitution ,
Whistleblower Awards ,
Whistleblowers
Despite predictions of a slow-down in enforcement under the Trump administration—and indications that enforcement in some areas has decreased in the past year1—2018 was yet again an active year for FCPA enforcement. The year...more
1/18/2019
/ Anti-Bribery ,
Anti-Corruption ,
Brazil ,
Bribery ,
Chief Compliance Officers ,
China ,
Compliance ,
Cooperation ,
Corporate Counsel ,
Corporate Investigations ,
Corruption ,
Credit Suisse ,
Criminal Investigations ,
Criminal Prosecution ,
Declination ,
Department of Justice (DOJ) ,
Enforcement ,
Enforcement Actions ,
Enforcement Statistics ,
Foreign Corrupt Practices Act (FCPA) ,
Panasonic ,
Petrobras ,
Securities and Exchange Commission (SEC) ,
Strategic Enforcement Plan ,
Voluntary Disclosure ,
Whistleblowers ,
Yates Memorandum
Busy Q1 Yields Several Significant FCPA Resolutions -
Overview -
On February 19, during the US Securities and Exchange Commission’s (SEC) annual “SEC Speaks” conference, Kara Brockmeyer, Chief of the SEC’s FCPA...more
3/25/2016
/ Anti-Bribery ,
Anti-Kickback Statute ,
Books & Records ,
Compliance ,
Cooperation ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Enforcement Actions ,
False Claims Act (FCA) ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Official ,
Internal Controls ,
Misrepresentation ,
Qualcomm ,
Securities and Exchange Commission (SEC) ,
Transparency