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Compliance Corruption China

Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory violations. ... more +
Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory violations.  In response to many corporate scandals evidencing rampant unethical business practices, many nations, including the United States, began passing strict regulatory frameworks aimed at curbing these abuses. Notable pieces of legislation in this area include the U.S. Foreign Corrupt Practices Act (FCPA), Sarbanes-Oxley (SOX), and the U.K. Bribery Act, to name a few. The foregoing statutes and the severe penalties often associated with them form the basis of many modern institutional compliance programs. less -
Adams and Reese LLP

International Compliance Digest – August 2024

Adams and Reese LLP on

August was another robust month in international trade that further signifies the need for corporations to invest in effective compliance programs. For starters, the DOJ unveiled a new program that incentivizes corporate...more

The Volkov Law Group

District Court Rejects Challenges to ITAR Criminal Charges

The Volkov Law Group on

On July 9, 2024, District Judge David Hale in Kentucky denied motions to dismiss and motions to suppress filed by four defendants against a criminal case involving ITAR charges for illegal exports of sensitive,...more

The Volkov Law Group

A Practical Guide to Compliance with the Uyghur Forced Labor Prevention Act (“UFLPA”)

The Volkov Law Group on

On December 31, 2021, President Joseph R. Biden, Jr. signed the the Uyghur Forced Labor Prevention Act (“UFLPA”) into law to address the ongoing exploitation of the ethnic minority Uyghur population by the government of the...more

Pollock Cohen LLP

China, FCPA, and SEC

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Introduction - Doing business with China is always complex. Add in the need for compliance with the Foreign Corrupt Practices Act (FCPA) and the challenges can be formidable. Companies operating in or with ties to China must...more

Thomas Fox - Compliance Evangelist

3M in China-Where Secret Travel = FCPA Violations

You know that when the Securities Exchange Commission (SEC) uses the word ‘secretly’ when discussing a corporate program, it is a seriously not good look. That is certainly the case in the recently announced Foreign Corrupt...more

The Volkov Law Group

3M Corp Pays SEC $6.5 Million to Resolve FCPA Charges

The Volkov Law Group on

The SEC is having a good year in prosecuting FCPA cases.  The SEC’s recent settlement with 3M Corp. for $6.5 million is its seventh corporate resolution for the year.  DOJ, which has been relatively quiet so far this year,...more

Orrick, Herrington & Sutcliffe LLP

SEC fines Dutch medical supplier $62 million to settle FCPA charges

The SEC recently announced that a global Dutch manufacturer of health technology products agreed to pay more than $62 million to settle claims that it allegedly violated the FCPA with respect to the sale of medical diagnostic...more

American Conference Institute (ACI)

[Event] 13th West Coast Forum on FCPA Enforcement and Compliance - June 14th - 15th, San Francisco, CA

Hosted by American Conference Institute, the 13th West Coast Forum on FCPA Enforcement and Compliance returns for another exciting year, providing the opportunity to connect with decision-makers from your industry, gather...more

The Volkov Law Group

Koninklijke Philips Pays SEC $62 Million to Resolve FCPA Violations in China

The Volkov Law Group on

After a long-running investigation, Koninklijke Philips (“Philips), a Dutch company, resolved FCPA violations in China by agreeing to pay the SEC $62 million.  Philips is a global manufacturer of medical equipment....more

World Law Group

2022 Anti-corruption Guide - China

World Law Group on

1. Is your country a member of the OECD Anti-Bribery Convention? No. 2. Is your country a member of any other bilateral or multilateral conventions on anti-corruption? Yes. China is a member of the United Nations...more

The Volkov Law Group

2022 OFAC and Sanctions Enforcement Predictions

The Volkov Law Group on

The Treasury Department’s Office of Foreign Asset Control (“OFAC”) has been a steady performer in this challenging pandemic environment.  Since the pandemic, OFAC has maintained a strong profile, while managing a difficult...more

The Volkov Law Group

A Deep Dive into WPP’s Bribery Schemes in India, China, Brazil and Peru (Part II of III)

The Volkov Law Group on

The SEC’s FCPA settlement with WPP for over $19.2 million provides a variety of bribery schemes in several high-risk venues. The schemes are instructive because they remind anti-corruption compliance professionals of the...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

The Herbalife FCPA Enforcement Action: Part 2 – Bribery Schemes and Numbers

Herbalife Nutrition Ltd (Herbalife) recently concluded a long running Foreign Corrupt Practices Act (FCPA) enforcement action with both the Department of Justice (DOJ) and Securities and Exchange Commission (SEC). Herbalife...more

Thomas Fox - Compliance Evangelist

The Herbalife FCPA Enforcement Action: Part 1 – Introduction

Herbalife Nutrition Ltd (Herbalife) recently concluded a long running Foreign Corrupt Practices Act (FCPA) enforcement action with both the Department of Justice (DOJ) and Securities and Exchange Commission (SEC). Herbalife...more

The Volkov Law Group

Herbalife FCPA Settlement is An Important Reminder: Global Companies Need to Focus on Foreign Government Touchpoints

The Volkov Law Group on

As we look past the Herbalife FCPA settlement with DOJ and the SEC for $123 million to resolve FCPA bribery and books and records violations, we are reminded of the variety of foreign government touchpoints and FCPA risks....more

The Volkov Law Group

Herbalife’s FCPA Settlement: Lessons Learned (Part III of III)

The Volkov Law Group on

Herbalife’s FCPA settlement is another one for books – the wreckage left includes two criminal indictments for Chinese officials who may never be apprehended, along with $123 million in penalties....more

The Volkov Law Group

Herbalife’s China Bribery Scheme (Part II of III)

The Volkov Law Group on

Herbalife’s bribery scheme in China stretched across the 28 provinces of China and even involved an Herbalife senior executive in its headquarters in Los Angeles, California.  DOJ has indicted Yangling Li, aka Jerry Li, and...more

Thomas Fox - Compliance Evangelist

Coronavirus Travel and Meeting Ban – An Opportunity for New Compliance Communications

It looks like travel will now be shut down, at least through the end of April, if not longer for most US companies. This travel ban may well also include a ban on face-to-face gatherings of one or more persons. Of course that...more

The Volkov Law Group

FCPA Predictions for 2020 (Part III of III)

The Volkov Law Group on

It is time to break out the crystal ball for FCPA 2020 Predictions.  In preparing for this, I always rely on my past admiration of Carnac the Magnificent....more

Thomas Fox - Compliance Evangelist

Bribery Schemes from 2019 FCPA Enforcement Actions

In today’s blog post, I want to look at some of the more unusual bribery schemes from Foreign Corrupt Practices Act (FCPA) enforcement actions in 2019. Some of these schemes were not unusual but they were accomplished with...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

Billion Dollar Baby: Ericsson FCPA Enforcement Action – Part 5: Lessons Learned for the Compliance Professional

Last week the Justice Department (DOJ) announced a resolution of the long standing Foreign Corrupt Practices Act (FCPA) enforcement action involving Telefonaktiebolaget LM Ericsson (Ericsson), a multinational networking and...more

Thomas Fox - Compliance Evangelist

Billion Dollar Baby: Ericsson FCPA Enforcement Action - Part 4: The Double Whammy in Penalties

Last week the Justice Department (DOJ) announced a resolution of the long standing Foreign Corrupt Practices Act (FCPA) enforcement action involving Telefonaktiebolaget LM Ericsson (Ericsson), a multinational networking and...more

Thomas Fox - Compliance Evangelist

Billion Dollar Baby: Ericsson FCPA Enforcement Action – Part 3: Internal Control Failures

Last week the Justice Department (DOJ) announced a resolution of the long standing Foreign Corrupt Practices Act (FCPA) enforcement action involving Telefonaktiebolaget LM Ericsson (Ericsson), a multinational networking and...more

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