Wicked Coin: The "Fat Leonard" Scandal
Navigating Civil Standing Requirements for Defense Success — RICO Report Podcast
Episode 330 – Halyna Senyk on Anti-Corruption Progress in Ukraine
Managing Corruption Risk in Latin America
The Presumption of Innocence Podcast: Episode 38 - A Blueprint for Compliance: The Fraud Pentagon Theory
Episode 323 - Carlos Villagran Discusses Rebuilding a Corporate Culture After a Crisis
The Presumption of Innocence Podcast: Episode 34 - A Conversation With Jesse Eisinger, Author of 'The Chickenshit Club: Why the Justice Department Fails to Prosecute Executives'
Episode 317 -- A Deep Dive into the Trafigura FCPA Settlement
What's Going on with FCPA?
Episode 316 -- DOJ Announces New Whistleblower Policy
RICO Vicarious Liability — RICO Report Podcast
Episode 313 -- The Coming Criminal Corporate Sanctions Enforcement Storm
RICO Damages — RICO Report Podcast
Corruption, Crime & Compliance: DOJ’s Shifting Approach to Recidivism and Self-Disclosure
Episode 305 -- Deep Dive into SAP FCPA Settlement
AGG Talks: Antitrust and White-Collar Crime Roundup - Developments in the Trump Indictments and Recent Supreme Court Issues
Episode 300 -- Deep Dive into DOJ FCPA Settlement with Two U.K. Reinsurance Companies for Bribery in Ecuador
AGG Talks: Antitrust and White-Collar Crime Roundup - Examining the Latest Updates in the Pending Criminal and Civil Litigation Against Trump
The EU Directive for Combatting Corruption
Episode 295 -- Deep Dive into the Albemarle DOJ and SEC FCPA Settlements
Six months after the passage of the Crimes Legislation Amendment (Combatting Foreign Bribery) Act 2024, the Australian government has published important guidance on the “adequate procedures” companies should have in place in...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
2024 represents the 25th anniversary of the Organisation for Economic Co-operation and Development (OECD) Convention on Combating Bribery of Foreign Public Officials, which has now been signed by 46 countries—including eight...more
FEPA contains a broad prohibition on corrupt activity and applies to a broad category of public officials. First, FEPA makes it unlawful for any foreign official to “demand, seek, receive, accept, or agree to” receive...more
Foreign Corrupt Practices Act (“FCPA”) enforcement continues to slowly rebound from pre-pandemic levels. In 2023, the Department of Justice (“DOJ”) and the Securities and Exchange Commission (“SEC”) resolved 13 corporate FCPA...more
After the internal report comes in and you have properly triaged the matter, you need to scope out and investigate it, promptly, thoroughly and with competent personnel. In the 2023 ECCP, provided these series of questions...more
China’s anti-corruption laws have been stringent for many years. On 1 January 1980, the Criminal Law of the People’s Republic of China (the “PRC Criminal Law”) containing the criminal offences of bribery and corruption came...more
This week we are taking a deep dive into the SAP Foreign Corrupt Practices Act (FCPA) enforcement action. In it, SAP agreed to pay the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) approximately...more
When it comes to FCPA enforcement and expectations, DOJ has moved the goalposts. Some would argue that DOJ has been consistent all along. The truth, like most issues, lies somewhere between the extremes....more
The Justice Department’s FCPA enforcement record for 2024 was slow. This trend was unexpected, contrary to my own predictions and of various other prognosticators. It is hard to explain why this slowdown occurred....more
On December 14, 2023, Congress passed the Foreign Extortion Prevention Act (“FEPA”) in an effort to address certain deficiencies inherent in the current iteration of the Foreign Corrupt Practices Act (“FCPA”), as part of the...more
2023 was a very significant year for every compliance practitioner and compliance program. While there was a paucity of corporate enforcement actions under the Foreign Corrupt Practices Act (FCPA), there were significant...more
Last week at the 40th American Conference Institute (ACI) International Conference on the FCPA, government enforcement agencies such as the Department of Justice (DOJ), Securities and Exchange Commission (SEC), and UK Serious...more
UN Corruption Convention’s Ratification - In October 2003, the General Assembly officially ratified the United Nations Convention against Corruption (“Corruption Convention”). Since that time, a total of 190 countries have...more
Summary - The Department of Justice (DOJ) has created the International Corporate Anti-Bribery initiative (ICAB), which aims to strengthen the United States’ global efforts in combating corruption through enhanced...more
While the Department of Justice (DOJ) has initiated at least two new Foreign Corrupt Practices Act (FCPA) enforcement actions against U.S. companies, it has also announced several decisions not to prosecute—most recently...more
Survey: Tech gaps, third parties pose biggest ABAC threats - Compliance professionals surveyed regarding their anti-bribery and corruption efforts (ABAC) indicated resource support deficiencies in areas including staffing...more
Hosted by C5 Group, the 9th Anti-Corruption Conference in Paris returns for another exciting year with curated programming that will shed light on important issues at the forefront....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 enforcement developments from the past...more
The European Commission has published a proposed Directive which, building on measures already in place, would require member states to incorporate uniform anti-bribery measures into their laws. Whilst most EU member states...more
On April 17, 2023, the Wolfsberg Group (the "Group") issued updated guidelines for financial institutions ("FI") relating to Anti-Bribery and Corruption ("ABC") Compliance Programs. Although the guidance is not binding, it...more
With the ever-changing landscape of regulations and laws, it is becoming increasingly difficult for companies to keep up and remain compliant. In this 5-part blog post series, sponsored by Diligent, I will consider the full...more
Basic Compliance & Ethics Academy overview - Ideal for practitioners who have some compliance knowledge and are ready for a deeper dive, SCCE’s Basic Compliance & Ethics Academy provides comprehensive, classroom-style...more
Ericsson, a multinational telecommunications company, based in Sweden, settled its breach of its 2019 Deferred Prosecution Agreement, agreed to enter a guilty plea and pay a $206 million penalty. In 2019, Ericsson entered...more
Foreign Corrupt Practices Act (“FCPA”) enforcement has yet to rebound from the immediate pre-pandemic period. In 2022, DOJ and SEC resolved eight corporate FCPA matters for $878 million, including four resolutions coordinated...more