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Bribery Chief Compliance Officers Department of Justice (DOJ)

American Conference Institute (ACI)

The Foreign Extortion Prevention Act: Much Ado About Nothing?

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

NAVEX

Risk & Compliance as a Strategic Imperative for the Board

NAVEX on

In an era marked by heightened global regulatory scrutiny and enforcement, the landscape of risk and compliance is undergoing an evolution making the strategic imperative for effective, risk-based compliance initiatives...more

American Conference Institute (ACI)

[Event] Summit on Anti-Corruption & Compliance Programs - March 22nd - 23rd, Mexico City, Mexico

Hosted by American Conference Institute, the Mexico Summit on Anti-Corruption & Compliance Programs returns for another exciting year with curated programming that shines a global spotlight on anti-corruption compliance...more

Latham & Watkins LLP

DOJ’s Updated Corporate Enforcement Policy Aims to Incentivize Compliance

Latham & Watkins LLP on

Companies that self-disclose, cooperate, and remediate could benefit from significantly reduced fines and possible declinations even in cases with aggravating factors. In a speech at Georgetown University Law Center on...more

Dorsey & Whitney LLP

DOJ Announces Additional Incentives for Corporate Cooperation in Criminal Enforcement

Dorsey & Whitney LLP on

On January 17, 2023, Assistant Attorney General for the United States Department of Justice Kenneth A. Polite Jr. announced significant revisions to the Criminal Division’s Corporate Enforcement Policy (“CEP”). Four months...more

Thomas Fox - Compliance Evangelist

Profit Sharing as Bribery: The Honeywell FCPA Enforcement Action: Part 1 – Introduction

To close out 2022 in Foreign Corrupt Practices Act (FCPA) enforcement actions, the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) both announced settlements of FCPA enforcement actions with Honeywell...more

Thomas Fox - Compliance Evangelist

What 2022 Brought to Compliance

2022 was a very significant year for every compliance practitioner and compliance program. While there was a paucity of corporate FCPA enforcement actions, there were three enforcement actions were significant with multiple...more

Thomas Fox - Compliance Evangelist

ABB FCPA Resolution: Part 1 – Introduction

Late last week, the Department of Justice (DOJ) announced a highly anticipated resolution of Foreign Corruption Practices Act (FCPA) violation involving the Swiss construction giant, ABB Ltd. The most obvious significance is...more

Paul Hastings LLP

Sign on the Dotted Line: Compliance Certifications by CEOs and CCOs A Likely Requirement

Paul Hastings LLP on

As it continues its focus not just on enforcement, but on compliance, members of the U.S. Department of Justice have foreshadowed a sea change for Chief Executive Officers and Chief Compliance Officers in corporate...more

American Conference Institute (ACI)

[Event] Mexico Summit on Anti-Corruption & Compliance Programs - March 22nd - 23rd, Mexico City, Mexico

Join the Go-To Event of the Year for Mexico’s Anti-Corruption Community. The annual ACI’s Anti-Corruption Summit in Mexico is back to Mexico City on March 22-23, 2022! This is the most important anti-corruption compliance...more

Thomas Fox - Compliance Evangelist

2021 – The Year in FCPA Enforcement

There was a paucity of Foreign Corrupt Practices Act (FCPA) enforcement actions in 2021. However, the few enforcement actions announced did provide significant lessons for every compliance professional....more

Thomas Fox - Compliance Evangelist

What 2021 Brought to Compliance

2021 was a very significant year for every compliance practitioner and compliance program. While there was a paucity of corporate FCPA enforcement actions, the three enforcement actions were significant with multiple lessons...more

Thomas Fox - Compliance Evangelist

Foster Wheeler Settles Corruption Allegations – Silk Shirts and Corruption

I am continuing my review of the Amec Foster Wheeler (Foster Wheeler) international corruption enforcement action. Today, I want to focus on the underlying facts of the corruption. These facts are laid out in the Department...more

Miller Canfield

Record Level of FCPA Enforcement in 2020 Highlights Key Risk Areas

Miller Canfield on

The year 2020 witnessed a record level of $2.78 billion in corporate fines and penalties from enforcement of the Foreign Corrupt Practices Act (FCPA) by the U.S. Department of Justice (DOJ) and the U.S. Securities and...more

Thomas Fox - Compliance Evangelist

The Herbalife FCPA Enforcement Action: Part 4 – Final Thoughts

We are the end of my multi-part exploration of the Herbalife Nutrition Ltd (Herbalife) Foreign Corrupt Practices Act (FCPA) enforcement action with both the Department of Justice (DOJ) and Securities and Exchange Commission...more

Thomas Fox - Compliance Evangelist

500th Anniversary Episode

We are here and today I am extraordinarily honored to post my 500th Anniversary podcast. Now, I switch seats to be the guest as I am interviewed by Gregg Greenberg, the General Manager of C-Suite Radio. We take a look back at...more

Thomas Fox - Compliance Evangelist

The Significance of Opinion Release 20-01

For the first time in six years, the Department of Justice (DOJ) has released an Opinion Release, denominated 20-01. At first blush it appears to be a straight-forward recitation of the equivalent of black letter law in the...more

Holland & Knight LLP

Lessons Learned from the Airbus Anti-Corruption Settlements

Holland & Knight LLP on

In late January 2020, Airbus agreed to pay nearly $4 billion and to take a number of remedial measures in order to resolve alleged corruption violations with the French National Financial Prosecutor's Office (PNF), the United...more

WilmerHale

$1 Billion Ericsson Resolution, Three Jury Verdicts Cap Off Busy Fourth Quarter for US FCPA Enforcement

WilmerHale on

On December 6, 2019, the Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) agreed to resolve allegations that multinational telecommunications company Telefonaktiebolaget LM Ericsson (Ericsson or...more

Thomas Fox - Compliance Evangelist

The Unaoil Execs Guilty Pleas - The Ahsanis Criminal Information

Nine years ago, on November 4, 2010, was Panalpina Settlement Day which made history for the single largest number of companies to simultaneously settle Foreign Corrupt Practices Act (FCPA)-related violations. ...more

Thomas Fox - Compliance Evangelist

TechnipFMC FCPA Enforcement Action - Lessons for the Compliance Professional

The month of June, 2019, closed out one of the most interesting half-years in the Foreign Corrupt Practices Act (FCPA) realm....more

Thomas Fox - Compliance Evangelist

Fresenius FCPA Enforcement Action

The long-awaited Fresenius Medical Care AG & Co. KGaA (FMC) Foreign Corrupt Practices Act (FCPA) enforcement action was recently announced. It involved massive multi-year and multi bribery schemes by the company in multiple...more

Thomas Fox - Compliance Evangelist

MTS FCPA Settlement and Karimova Indictment: Lessons for Compliance Practitioners

This white paper will examine the background facts of the Mobile TeleSystems PJSC (MTS) FCPA case, provide a detailed review of the bribery schemes involved, the compliance failures of MTS and its actions during the...more

Thomas Fox - Compliance Evangelist

Follow the Money: The Polycom and Eletrobras FCPA Enforcement Actions

The Polycom and Eletrobras FCPA enforcement actions present several important lessons for Chief Compliance Officers. Tom Fox explores....more

WilmerHale

Foreign Corrupt Practices Act Alert: Global Anti-Bribery Year-in-Review: 2018 Developments and Predictions for 2019

WilmerHale on

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

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