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
The U.S. Securities and Exchange Commission (“SEC”) recently instituted proceedings against Deere & Company (“John Deere”), a leading global manufacturer of agricultural and heavy machinery, for multiple violations of the...more
Power and corruption … two sides of a Wicked Coin. In this podcast, hosts Tatiana Sainati, co-chair of Wiley’s Global Disputes Practice, and Diana Shaw, a partner in Wiley’s White Collar & Government Investigations Practice...more
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
Last month, I wrote a blog post on the tone at the top, exemplified in Star Trek’s Original Series episode, Devil in the Dark. Based on the response, some passionate Star Trek fans are out there. I decided to write a series...more
In 2023, the number of federal corporate prosecutions remained far below the 25-year average after two consecutive years of increases. ..The DOJ’s Fraud Section secured just $690 million in penalties across eight...more
In March 2024, at the American Bar Association’s 39th National Institute on White Collar Crime, Deputy Attorney General (“DAG”) Lisa Monaco announced that the Department of Justice (“DOJ” or the “Department”) intended to...more
I recently spoke with the Foreign Corrupt Practices Act (FCPA) Handbook authors Robert Tarun and Peter Tomczak from Baker McKenzie for a two-part podcast episode. The depth of knowledge and experience in white-collar crime,...more
The Serious Fraud Office (SFO) recently published its new five-year strategy for 2024-2029 (the Strategy), setting out its ambitious aspirations to become a “pre-eminent specialist, innovative and collaborative agency which...more
Construction is a $1.7 trillion industry worldwide, contributing between 5 and 7 percent of GDP in most countries. However, it is also an industry that is highly vulnerable to corruption due to its inherent characteristics....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
Readers of prior Firm client alerts in the white-collar criminal space will no doubt recall the Supreme Court's recent trend of scaling back the powers of the Department of Justice (DOJ) in prosecuting public corruption...more
The sentencing of Romy Andrianarisoa, the first ever foreign public official to be convicted under the Bribery Act 2010, provides important takeaways. On 10 May 2024, Romy Andrianarisoa was sentenced to three-and-a-half...more
Enforcement of the Foreign Corrupt Practices Act of 1977 relies heavily on whistleblowers, both in America and abroad. If you have information about a potential violation of the law and want to report it to the authorities,...more
One of the best examples I have recently seen on the power of data driven compliance is playing out in real time in the NBA. It is the Jontay Porter betting scandal. This event had driven home why transparency, coupled with...more
The Justice Department is rightly trumpeting its successful sweep of the commodities trading industry. DOJ’s success is reflected in its six separate corporate resolutions and 20 individual convictions, resulting in over...more
Trafigura’s bribery scheme resembles the same schemes implemented by its significant competitors — Vitol, Glencore, Gunvor. At the core of the conduct, Petrobras and Brazilian government officials collected bribes in...more
On the heels of the Gunvor FCPA settlement for $661 million, DOJ announced its settlement with Trafigura, the latest commodities trading company to fall under DOJ’s FCPA Sweep against the industry. Trafigura joined the list...more
We conclude our exploration of the resolution of the FCPA enforcement action involving the Swiss trading firm G Trafigura Beheer B.V. (Trafigura), an international commodity trading company with its primary operations in...more
We continue our exploration of the resolution of the FCPA enforcement action involving the Swiss trading firm trading firm G Trafigura Beheer B.V. (Trafigura), an international commodity trading company with its primary...more
DOJ has been on a public relations campaign to push a simple message for corporations: if companies learn of misconduct, companies should disclose such misconduct to earn valuable benefits. The quintessential question...more
We are thrilled to introduce the inaugural issue of our quarterly White Collar newsletter, a dedicated resource from Benesch’s White Collar, Government Investigations & Regulatory Compliance Practice Group. Each issue...more
We continue our exploration of the resolution of the FCPA enforcement action involving the Swiss trading firm G Trafigura Beheer B.V. (Trafigura), an international commodity trading company with its primary operations in...more
In March 2024, the Department of Justice (DOJ) announced the resolution of a Foreign Corrupt Practices Act (FCPA) enforcement action involving the Swiss trading firm G Trafigura Beheer B.V. (Trafigura), an international...more
The Department of Justice’s blockbuster FCPA settlement with Gunvor restores the credibility of DOJ’s pronouncements of DOJ’s commitment to aggressive FCPA enforcement. While I have questioned DOJ’s commitment to its...more
As noted in this series, Gunvor received a 25% discount despite substantial violations of the FCPA that extended into the corporate offices. The company made multiple changes, which compliance professionals should study. We...more