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Bribery Disgorgement Compliance

The Volkov Law Group

DOJ Issues New FCPA Declination: Boston Consulting Group Pays $14.4 Million

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The Justice Department is encouraging companies to voluntarily disclose criminal violations — “Come in and confess” and DOJ offers promises of a declination.  But even a declination comes with a requirement — the company has...more

Adams and Reese LLP

Beyond Borders: Navigating Global Business Compliance with the FCPA

Adams and Reese LLP on

On March 7th, the Department of Justice (DOJ) announced a new whistleblower reward program intended to help prosecutors bring more foreign corruption cases. Under the new program, individuals who report corporate misconduct...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for November 2023

Morrison & Foerster LLP on

Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption law and enforcement developments from the past...more

Thomas Fox - Compliance Evangelist

Albemarle FCPA Enforcement Action: Part 1 – Background

Last week, Albemarle Corporation (Albemarle), a publicly traded specialty chemicals manufacturing company headquartered in North Carolina, agreed to pay more than $218 million to resolve investigations by the U.S. Department...more

The Volkov Law Group

Albemarle Settles DOJ and SEC FCPA Cases for $218 Million (Part I of III)

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Albemarle Corporation (Albemarle), a specialty chemicals manufacturing company located in Charlotte, North Carolina, agreed to pay more than $218 million to settle FCPA investigations with DOJ and the SEC stemming from...more

The Volkov Law Group

Corsa Coal Earns Declination and Agreed to Disgorge $1.2 Million

The Volkov Law Group on

The Justice Department has been pushing its voluntary self-disclosure program and changes to its Corporate Enforcement Policy, in an attempt to increase FCPA enforcement cooperation.  The Golden Ring for every company facing...more

Bradley Arant Boult Cummings LLP

DOJ Expands Availability of Declinations with Disgorgement for Corporations that Self-Disclose Misconduct

Earlier this month, DOJ updated its Corporate Enforcement Policy (CEP). Aimed at encouraging companies to voluntarily disclose unlawful conduct, the updated CEP gives greater opportunities to companies to avoid charges...more

The Volkov Law Group

Catching Up with FCPA News

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DOJ closed out its FCPA enforcement year in 2022 with two significant settlements, the ABB and Honeywell cases.  Aside from these two big settlements, there was a flurry of other actions in the last quarter of 2022....more

The Volkov Law Group

Oracle Joins Ranks of FCPA Recidivists: Settles SEC Case for $23 Million (Part I of II)

The Volkov Law Group on

Oracle Corporation settled its second FCPA case in ten years.  Oracle agreed to pay $23 million to resolve allegations that its subsidiaries in Turkey, India and the United Arab Emirates maintained slush funds to bribe...more

The Volkov Law Group

Tenaris Pays SEC $78 Million to Resolve FCPA Violations

The Volkov Law Group on

The SEC announced another FCPA settlement in 2022.  FCPA enforcement, in general, is picking up.  Tenaris, a global supplier of steel pipes and related services for the energy industry, agreed to pay the SEC $78 million to...more

The Volkov Law Group

DOJ Issues Declination to Global Advertising Company Under FCPA Enforcement Policy

The Volkov Law Group on

The Justice Department continues its enforcement “silence” with no major corporate prosecutions announced this year.  It is an interesting question but it appears that the wheels have ground to a halt, with one major...more

Cadwalader, Wickersham & Taft LLP

DOJ and SEC Update FCPA Resource Guide for 2020 – What’s New and What Does It Mean?

On July 3, 2020, the Department of Justice (“DOJ”) and Securities and Exchange Commission (“SEC”) updated their 2012 joint guidance on the Foreign Corrupt Practices Act (“FCPA”) in the SEC and DOJ’s FCPA Resource Guide...more

Jones Day

FCPA 2019 Year in Review

Jones Day on

In the third year of the Trump Administration, the biggest Foreign Corrupt Practices Act ("FCPA") headlines were record corporate fines and penalties, and a banner year of individual FCPA enforcement highlighted by three DOJ...more

Skadden, Arps, Slate, Meagher & Flom LLP

Ericsson Agrees To Pay Over USD $1 Billion To Settle FCPA Charges

On December 6, 2019, Telefonaktiebolaget LM Ericsson (Ericsson or the Company), resolved long-running investigations by the U.S. Department of Justice (DOJ) and the U.S. Securities and Exchange Commission (SEC) into the...more

Thomas Fox - Compliance Evangelist

Top SEC Enforcement Actions from 2019

Yesterday, I considered five Department of Justice (DOJ) Foreign Corrupt Practices Act (FCPA) enforcement actions. Today, I want to look at key FCPA enforcement actions by the Securities and Exchange Commission (SEC)....more

Thomas Fox - Compliance Evangelist

Year End (FCPA) Closeouts: Quad/Graphics, Barclays and Westport Fuel Systems

The US government fiscal year ends today. Just as in the business world, where many companies try and clear out any unexecuted deals or open contracts, we saw the Securities and Exchange Commission (SEC) clear out three...more

Thomas Fox - Compliance Evangelist

Juniper Networks FCPA Enforcement Action-Speak Sternly and Enhance Controls

Last week Juniper Networks, Inc. (JNPR) resolved their long-standing Foreign Corruption Practices Act (FCPA) enforcement action by settling with the Securities and Exchange Commission (SEC) via a Cease and Desist Order...more

Thomas Fox - Compliance Evangelist

Walmart FCPA Enforcement Action: Part 1 – Introduction

The big one finally is resolved. The long-awaited Walmart Inc. (Walmart) Foreign Corrupt Practices Act (FCPA) enforcement action was announced yesterday. This massive case came in with multiple documents, a long list of...more

Thomas Fox - Compliance Evangelist

Following the Money Through Distributors: The Polycom FCPA Enforcement Action

Now that Trump has shut down the government, it may be sometime before there is another Foreign Corrupt Practices Act (FCPA) enforcement action announced. However, this past week we had two which were quite interesting and...more

Thomas Fox - Compliance Evangelist

The Vantage Drilling FCPA Enforcement Action

Last week the Vantage Drilling International (Vantage) Foreign Corrupt Practices Act (FCPA) enforcement action with the Securities and Exchange Commission (SEC) was announced via an Administrative Order(Order)....more

The Volkov Law Group

Petrobas Closes Out “Massive” Corruption Investigations and Litigation

The Volkov Law Group on

When it comes to a poster-child for corrupt organizations, there is very little competition that can eclipse Petrobas, the Brazilian state-owned oil and gas company. ...more

Thomas Fox - Compliance Evangelist

Brighton Rock and the UTC FCPA Enforcement Action

According to Harry Cassin, writing in the FCPA Blog, “In late 2013 and early 2014, United Technologies self-disclosed to the DOJ, SEC, and the SFO the status of an internal investigation regarding a non-employee sales rep for...more

The Volkov Law Group

DOJ Issues Declination and Disgorgement Under FCPA Corporate Enforcement Policy

The Volkov Law Group on

In a recently released letter, the Justice Department issued a declination to the Insurance Corporation of Barbados Limited (ICBL) for violations of the FCPA under the FCPA Corporate Enforcement Policy. DOJ required ICBL to...more

Thomas Fox - Compliance Evangelist

The FCPA Corporate Enforcement Policy in Action-Part I

We had three major Foreign Corrupt Practices Act (FCPA) cases resolved in Q2 2018. They all reached different resolutions under the new FCPA Corporate Enforcement Policy and the new anti-piling on policy....more

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