In 2022, the DOJ and the SEC resolved a total of ten corporate enforcement actions under the FCPA, more than double the number in the previous year. While the average corporate penalties only slightly increased to $168...more
On March 2, 2023, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS), the Department of the Treasury’s Office of Foreign Asset Control (OFAC) and the Department of Justice issued a joint compliance note...more
The world’s response to Russia’s invasion of Ukraine dominated the first quarter of 2022, as the US and its international partners coordinated efforts to impose unprecedented sanctions designed to isolate the Russian...more
5/4/2022
/ Biden Administration ,
China ,
Cuba ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Foreign Policy ,
Iran ,
North Korea ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Sanctions ,
Securities and Exchange Commission (SEC) ,
Ukraine
On October 28, 2021, at the American Bar Association’s National Institute on White Collar Crime, Deputy Attorney General Lisa O. Monaco announced revisions to the Department of Justice’s policies, all designed to strengthen...more
FOURTH QUARTER 2019 -
- Congress closes the year by passing new sanctions against China over human rights concerns, while OFAC clarifies the scope of recent actions against Chinese shipping companies.
- In the wake of...more
1/15/2020
/ AML/CFT ,
China ,
Compliance ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Export Controls ,
Exxon Mobil ,
Human Rights ,
Iran ,
Iran Sanctions ,
New Guidance ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Sanctions ,
Voluntary Disclosure
The January 2019 FCPA Digest is an invaluable compendium of all FCPA-related developments in 2018, including US foreign bribery proceedings and criminal prosecutions, DOJ foreign bribery civil actions, SEC actions, DOJ...more
1/3/2019
/ Bribery ,
Chief Compliance Officers ,
Compliance ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Jurisdiction ,
Kokesh v SEC ,
Serious Fraud Office (SFO) ,
Settlement ,
Subsidiaries ,
UK ,
White Collar Crimes ,
Yates Memorandum
Shearman & Sterling’s bi-annual Trends & Patterns in FCPA Enforcement report provides insightful analysis of recent enforcement trends and patterns in the US, the UK and elsewhere, as well as helpful guidance on emerging best...more
1/4/2017
/ AstraZeneca ,
Bribery ,
Compliance ,
Corporate Counsel ,
Declination ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Official ,
GlaxoSmithKline ,
Internal Controls ,
JPMorgan Chase ,
Novartis ,
Nu Skin ,
Odebrecht ,
Popular ,
Qualcomm ,
Securities and Exchange Commission (SEC) ,
Teva Pharmaceuticals ,
Voluntary Disclosure ,
Whistleblowers ,
Yates Memorandum
On April 5, 2016, the United States Department of Justice, Criminal Division, Fraud Section launched a one-year Pilot Program that invites companies to self-report potential violations of the Foreign Corrupt Practices Act...more
Recent enforcement actions by the Department of Justice and Securities and Exchange Commission have raised the profile of corruption in international sport and highlight unique FCPA compliance concerns. This note will explain...more
6/15/2015
/ BHP Billiton ,
Bribery ,
Compliance ,
Corporate Counsel ,
Corruption ,
Department of Justice (DOJ) ,
Football ,
Foreign Corrupt Practices Act (FCPA) ,
Indictments ,
Match Fixing ,
Olympics ,
Popular ,
Securities and Exchange Commission (SEC) ,
Soccer ,
Sports ,
World Cup
Recent OFAC and DOJ actions have focused on certain entities – overseas financial institutions – and particular conduct – US dollar clearing and associated “stripping.” The DOJ’s recent $232 million settlement and negotiated...more
4/17/2015
/ Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Extraterritoriality Rules ,
Facilitation Payments ,
FFI ,
Internal Controls ,
Manufacturers ,
Office of Foreign Assets Control (OFAC) ,
Sanctions ,
Schlumberger