Wicked Coin: The "Fat Leonard" Scandal
Corruption, Crime & Compliance: Deep Dive into The Gunvor FCPA Settlement
Episode 307 -- Sanctions Enforcement Review and Predictions for 2024
Episode 300 -- Deep Dive into DOJ FCPA Settlement with Two U.K. Reinsurance Companies for Bribery in Ecuador
Episode 296 -- Deep Dive into Clear Channels SEC Settlement of FCPA Violations
Episode 294 -- Catch Up on OFAC Enforcement: 3M and Emigrant Bank
The Maritime Anti-Corruption Network: An In-Depth Conversation
Season 2 - Episode 2 - A Whistleblowers Nightmare: The Uncovering of the 1Malaysia Development Berhad Scandal
The Justice Insiders Podcast: Varsity Blues Reversals Turn DOJ Red
Corruption, Crime, and Compliance - The Ericsson FCPA DPA Breach Settlement
Episode 258 -- Deep Dive into ABB FCPA Settlement
Corruption Crime & Compliance - Deep Dive into the ABB FCPA Case
Life with GDPR - The ABB Enforcement Action from a UK Perspective
The Corruption Files - Episode 15 - The ABB Settlement
The Line Between Gift Giving and Bribery
The Corruption Files - Episode 14 - Walmart with Tom Fox and Michael DeBernardis
Compliance Into The Weeds - Lafarge and the Cost of Moral Bankruptcy
The New Cold War: Risk, Sanctions, Compliance Episode 21: "Interview with Drago Kos of the OECD Working Group on Bribery"
The Justice Insiders: FIFA Corruption Trial – Will the Feds Score Another Goal?
The Presumption of Innocence Podcast: Episode 5 - Doing Business Overseas: The Foreign Corrupt Practices Act
On August 1, 2024, the U.S. Department of Justice (“DOJ”) announced its new “Corporate Whistleblower Awards Pilot Program” (“DOJ Program”), a three-year initiative managed by DOJ’s Money Laundering and Asset Recovery Section....more
On May 10, 2024, Romy Andrianarisoa, former Chief of Staff to the President of Madagascar, was convicted for soliciting bribes from Gemfields Group Ltd (Gemfields), a UK-based mining company specializing in rubies and...more
We asked our global white collar crime team for their views on key challenges in 2023 for in‑house investigations teams and white collar crime lawyers, and how to manage the associated risks. Here are their top ten....more
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 case developments from the past month,...more
In Part 2 of Investigation Week, I take up the topic of your investigation protocol. Under Part 1, Section D. Confidential Reporting Structure and Investigation Process, it stated in part, Properly Scoped Investigation...more
Our Basic Academies are ideal for professionals with some compliance knowledge and experience who are ready to support, enhance and manage a comprehensive compliance program. They are taught by compliance professionals,...more
Aerospace, defense, and government services – tighter control ahead - 2020 was an eventful year for companies in the aerospace, defense, and government services (ADG) sector. The industry saw arguably the largest...more
Contrary to some expectations, the Trump Administration Department of Justice imposed record penalties under the U.S. Foreign Corrupt Practices Act from 2017 through 2020. But in each of those years, fewer and fewer new FCPA...more
In our Quarterly Review, we bring you important UK developments relating to business crime, investigations and regulatory enforcement from the last three months. We commented last month that the scale of the impact of the...more
Mario Draghi presided over his final ECB meeting yesterday, with the central bank deciding to hold rates steady and let current stimulus measures play out for the time being. His departure (and the arrival of former IMF chief...more
The FCPA prohibits an offer, payment, promise or the authorization of a payment of money or anything of value (a/k/a bribery) to a foreign official for the purpose of obtaining or retaining business....more
We are now half way (hopefully) through what is predicted to be the largest amount of rain seen in one week by the city of Houston and its surrounding environs in the city’s recorded history. First and foremost, my deepest...more
The guidance issued by the DOJ in connection with the Pilot Program and recent declinations state that disclosure, remediation and cooperation are essential to any favorable resolution with the government. Six months...more
For the first time, the Securities and Exchange Commission has brought an FCPA enforcement action premised entirely on a one-time charitable contribution. On September 20, 2016, the SEC announced a settled FCPA...more
The enforcement action against manufacturer Nu Skin Enterprises highlights the risks of making charitable donations in high-risk countries without conducting meaningful anticorruption due diligence....more
In a rare enforcement action, the SEC settled an FCPA enforcement action for $766,000 for a charitable donation of $154,000 to improperly influence a high-ranking Chiese Communist party official to prevent a provincial agency...more
If you ask members of a corporate board or senior executives about the cost of an FCPA enforcement action, they will candidly acknowledge all of the costs – fines, penalties, and professional costs (e.g. legal, accounting,...more
You know things are getting bad when the Wall Street Journal (WSJ) questions a business’ moral authority. Things certainly cannot be much better when the regulators begin nosing around your own self-indulgence. What happens...more
In this episode, I review the corporate FCPA enforcement actions of 2013. ...more
One of the questions that GlaxoSmithKline PLC (GSK) will have to face during the next few years of bribery and corruption investigations is how an allegedly massive bribery and corruption scheme occur in its Chinese...more
As most readers of this blog know, I am a recovering trial lawyer. I almost always acted as defense counsel for corporations in my trial lawyer career....more