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
In 2021, Congress passed an emergency measure to save the U.S. Commodity Futures Trading Commission (CFTC) Whistleblower Program from financial collapse. This measure is set to expire at the end of September, threatening to...more
On March 7, 2024, the Deputy Attorney General of the US Department of Justice (“DOJ” or “Department”) announced a pilot program to encourage whistleblowers to report evidence of high-priority white collar crimes with the...more
Since December 2021, the U.S. Securities and Exchange Commission (SEC) and Commodity Futures Trading Commission (CFTC) have levied almost $3.0 billion in penalties for longstanding failures by 39 broker-dealers, swap dealers,...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
While Foreign Corrupt Practices Act (FCPA) enforcement activity has not come close to returning to the heights seen a few years ago, 2022 reflected significant increases from the prior year in both the number of cases against...more
On 24 May 2022, Glencore International AG announced a series of coordinated resolutions with various international enforcements agencies including the Department of Justice (”DOJ”), the Commodity Futures Trading Commission...more
Glencore’s settlement with DOJ and the CFTC revealed a plethora of manipulative, deceptive and corrupt conduct, which spanned from at least 2007 to 2018 and occurred in the United States and global oil markets, including...more
In a long-anticipated and major enforcement action, the Justice Department and the Commodities and Futures Exchange Commission resolved a sprawling investigation with Glencore International A.G. and Glencore Ltd, a...more
2020 saw continuity in CFTC leadership, programs, and direction from 2019. Overall, the Commission enjoyed an unusually heavy rulemaking calendar and continued the direction of its enforcement program from 2019. On the...more
As 2020 drew to a close, enforcement authorities throughout the United States and the Americas continued to investigate fraud, corruption, and other misconduct across the region. Below, we highlight some developments from...more
The Justice Department and the Securities and Exchange Commission had another record year of enforcement. In fact, the last four years of FCPA enforcement included two years of record enforcement – 2019 and 2020. After...more
Today, I conclude my four-part exploration of the Vitol Inc. (Vitol) Foreign Corrupt Practices Act (FCPA) enforcement action. Vitol agreed to pay a combined $135 million to resolve matters. Interestingly, also included in the...more
The Justice Department is coming to the close of a record FCPA enforcement year despite the disruptions caused by the pandemic. The Vitol case also represents the first parallel prosecution involving the Commodities Futures...more
The CFTC recently joined the host of other federal and state regulators who enforce anti-money laundering laws, by bringing three cases finding violations of CFTC Regulation 42.2. Regulation 42.2 requires futures commission...more
DOJ’s Cyber Digital Task Force’s report, “Cryptocurrency: An Enforcement Framework,” provides a comprehensive on the growing partnerships between DOJ and other offices within the executive branch....more
JP Morgan Chase (“JP Morgan”) is not having a positive year when it comes to government enforcement. JP Morgan is at the brink of a multi-billion dollar FCPA settlement for its involvement in the 1MDB corruption scandal in...more
Practitioners active in derivative markets regulated by the Commodity Futures Trading Commission (CFTC) are well familiar with the US Court of Appeals for the Eighth Circuit’s proclamation in 1971 that “[t]he methods and...more
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
On March 6, 2019, the Commodity Futures Trading Commission’s (CFTC or Commission) Division of Enforcement (Division) published an advisory on self-reporting and cooperation for violations of the Commodity Exchange Act (CEA)...more
The Department of Justice (DOJ) announced two Foreign Corrupt Practices Act (FCPA) enforcement actions earlier this week and the intertwined nature of these two enforcement actions informs today’s blog post....more
Upon discovering a potential violation, a company is often faced with the dilemma of whether to self-report the incident to its regulator or attempt to deal with the incident through exclusively internal means. On September...more