News & Analysis as of

Bribery Self-Reporting Foreign Corrupt Practices Act (FCPA)

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for May 2024

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

Vinson & Elkins LLP

DOJ and SEC Stick Stericycle with a Two-Year Monitorship, Despite Acknowledgment of Extensive Remedial Measures

Vinson & Elkins LLP on

In yet another indication that the Biden administration is continuing to ramp up white collar enforcement, the U.S. Department of Justice (“DOJ”) and Securities and Exchange Commission (“SEC”) announced on April 20, 2022 that...more

Vinson & Elkins LLP

Recent DOJ Prosecution Declination Supports Its Promise Of Leniency For Self-Reporting Violations Even When “Bags of Money” Are...

Vinson & Elkins LLP on

A recurring question of general counsel and chief compliance officers is whether their proactive investments in compliance programs, voluntary self-disclosure of issues, and cooperation will be meaningfully rewarded. For too...more

Butler Snow LLP

2019 Developments and Trends in the Foreign Corrupt Practices Act (FCPA) & Global Anti-Corruption Efforts, Part 2 of 3

Butler Snow LLP on

Previously, we introduced you to this topic and provided updates about the positive international trends in anti-corruption efforts, bribery, and the Organization for Economic Cooperation and Development (OECD). Today, we...more

Thomas Fox - Compliance Evangelist

TechnipFMC FCPA Enforcement Action-Lessons Learned

We continue our exploration of the TechnipFMC Foreign Corrupt Practices Act (FCPA) enforcement action by considering the actions taken by the company (or both separately before their merger) in response to their FCPA...more

Stinson - Corporate & Securities Law Blog

CFTC Issues Advisory on Violations of the Commodity Exchange Act Involving Foreign Corrupt Practices

The CFTC announced an Enforcement Advisory on self-reporting and cooperation for violations of the Commodity Exchange Act, or CEA, involving foreign corrupt practices. ...more

The Volkov Law Group

Parallel Universes: Antitrust Leniency and the FCPA Pilot Program

The Volkov Law Group on

The world of science fiction can be exhilarating. If you ever read The Foundation Trilogy or Martian Chronicles, you know what I mean. The concept of parallel universes has always been an intriguing idea where believers can...more

Skadden, Arps, Slate, Meagher & Flom LLP

Key Takeaways: Government Enforcement Investigations – Trends and Perspectives from the UK, US and China

On September 20, 2016, Skadden presented a seminar titled “Government Enforcement Investigations – Trends and Perspectives from the UK, US and China” in London. The UK Financial Conduct Authority (FCA) Director of Enforcement...more

Snell & Wilmer

The Foreign Corrupt Practices Act’s One-Year “Pilot Program” Nears The Halfway Mark

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The Foreign Corrupt Practices Act (“FCPA”) prohibits both United States and foreign corporations and nationals from offering or paying, or authorizing the offer or payment, of anything of value to a foreign government...more

Thomas Fox - Compliance Evangelist

The UK Bribery Act: SFO Procedures and DPA Process

A couple of recent articles about the UK Serious Fraud Office (SFO) caught my attention. One was on thebriberyact.com, entitled “Opinion: DPA’s must show greater benefits. We discuss the Criteria & Process for a DPA set out...more

Morrison & Foerster LLP

Top Ten International Anti-Corruption Developments for April 2016

In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international anti-corruption developments from the past month, with links to primary...more

The Volkov Law Group

Creating a Real Incentive for Self-Reporting FCPA Violations (Part II of II)

The Volkov Law Group on

Let’s start with a big “If.” I know that sounds like a real turn off but bear with me. Assuming that the Justice Department is ready to turn over a new approach to criminal enforcement and aggressively prosecute culpable...more

Dorsey & Whitney LLP

Dorsey Anti-Corruption Digest - April 2016

Dorsey & Whitney LLP on

Welcome to Dorsey & Whitney’s monthly Anti-Corruption Digest. In this digest, we draw together news of enforcement activity throughout the world and aim to reduce your information overload. Our London, Minneapolis, New York...more

NAVEX

Is the DOJ’s New FCPA Pilot Program an Offer You Can’t Refuse?

NAVEX on

Earlier this month, Assistant US Attorney Leslie Caldwell announced that the US Department of Justice’s Criminal Division Fraud Section will try to entice companies to self-report potential FCPA issues. The DOJ included...more

Miller Canfield

DOJ’s Fraud Section Issues Foreign Corrupt Practices Act Enforcement Plan and Guidance

Miller Canfield on

On April 5, 2016, the Department of Justice’s Fraud Section (“DOJ”) issued its Foreign Corrupt Practices Act (“FCPA”) Enforcement Plan and Guidance (“Guidance”), which announced (1) a more than doubling of DOJ resources...more

Holland & Knight LLP

DOJ Announces Pilot Program to Standardize Cooperation Credit in FCPA Cases

Holland & Knight LLP on

The Fraud Section of the U.S. Department of Justice’s (DOJ) Criminal Division has announced a new initiative to motivate companies to self-report violations of the Foreign Corrupt Practices Act (FCPA), cooperate with the...more

Troutman Pepper

DOJ Criminal Division Announces FCPA Pilot Program

Troutman Pepper on

The pilot program appears to put a tangible number on the potential amount of reduction in sanctions for cooperation, but in reality is not all that “new.” On April 5, the U.S. Department of Justice (DOJ) announced a...more

Manatt, Phelps & Phillips, LLP

Health Update - September 2015

Latest Healthcare False Claims Act Roundup and Top 3 Best Practices to Reduce Exposure - As the legal landscape in healthcare becomes increasingly complex, healthcare companies that receive federal program funds face...more

Morrison & Foerster LLP

With No Civil Penalty, Goodyear FCPA Settlement Highlights Benefits of Cooperation and Remedial Actions

The Securities & Exchange Commission (“SEC”) announced last week that it charged The Goodyear Tire & Rubber Company (“Goodyear”) with violating the Foreign Corrupt Practices Act (“FCPA”), and that Goodyear agreed to pay more...more

Stinson LLP

Dallas Airmotive, Inc.'s FCPA Matter Offers Practical Insights and Continuing Lessons

Stinson LLP on

On December 10, 2014, DOJ filed a criminal Information alleging (i) conspiracy and (ii) violation of the bribery provisions of the FCPA against Dallas Airmotive, Inc., an aircraft engine maintenance, repair and overhaul...more

Thomas Fox - Compliance Evangelist

FCPA Compliance and Ethics Report-Episode 31-the FCPA Year in Review, Corporate Enforcement Actions

In this episode, I review the corporate FCPA enforcement actions of 2013. ...more

Brooks Pierce

Ralph Lauren Escapes FCPA Problems with Minimized Damage

Brooks Pierce on

Often, enforcement officials at the SEC and the Justice Department express their wish that securities law violators own up to their (mis)conduct as soon it comes to light. That is, come to the government and explain what has...more

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