Public-Private Partnerships to Stem Corruption
Episode 339: Four Sanctions Cases Everyone Should Know
The Presumption of Innocence Podcast: Episode 45 - The Grit, Grace and Gift of Second Chances
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
We recently had a Foreign Corrupt Practices Act (FCPA) enforcement action that reminded me that everything old is new again in anti-corruption compliance. The Securities and Exchange Commission (SEC) FCPA enforcement action...more
In the world of corporate compliance, some very basic compliance lessons seem destined to be repeated. This was certainly clear from the recently announced Securities and Exchange Commission (SEC) Foreign Corruption Practices...more
The SEC’s recent settlement with Deere & Company for $9.9 million for FCPA violations is another textbook example of bribery schemes, which revealed the absence of a culture of compliance, and the circumvention of basic...more
While 2023 saw a slight increase in the number of FCPA enforcement actions from 2022, there was a marked decline in total penalties from the prior year. Last year, the DOJ and the SEC resolved a total of 14 corporate...more
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
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
Earlier this month, the U.S. Department of Justice (DOJ) announced its Corporate Whistleblower Awards Pilot Program (Program). The Program—which will last for three years—is designed to incentivize, through money awards,...more
On August 1, 2024, Deputy Attorney General Lisa Monaco announced the launch of DOJ’s Corporate Whistleblower Awards Pilot Program (Pilot Program). The Pilot Program, previewed by Monaco in March 2024, provides another avenue...more
In a world where corporate integrity and accountability are more crucial than ever, the Department of Justice (DOJ) ‘s Whistleblower Pilot Program announcement marks a pivotal moment for compliance professionals. This...more
After announcing at the ABA White Collar Crime Conference last winter that it would engage in a months-long "policy sprint," the U.S. Department of Justice (DOJ or Department) released its Corporate Whistleblower Awards Pilot...more
On August 1, 2024, the US Department of Justice’s (DOJ’s) Principal Deputy Assistant Attorney General of the Criminal Division, Nicole Argentieri, unveiled the highly anticipated details of DOJ’s Corporate Whistleblower...more
The increase in internal reporting comes at a critical time when government-sponsored whistleblower programs are maturing and expanding into new agencies. The SEC’s program continues to increase and received a record number...more
Just one day after Deputy Attorney General Lisa Monaco announced the U.S. Department of Justice’s (“DOJ’s” or “Department’s”) whistleblower pilot program on March 8, 2024, the DOJ’s Criminal Division highlighted its plans to...more
On March 7, 2024, Deputy Attorney General Lisa Monaco (“DAG Monaco”) gave the keynote address at the American Bar Association’s 39th National Institute on White Collar Crime. She addressed the success she views in the...more
The Department of Justice has announced yet another pilot program, adding to their “mix of carrots and sticks” designed “to promote responsible corporate citizenship.” The new whistleblower pilot program, which is still under...more
Over this series, I have reviewed the messages communicated by the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) from three key Foreign Corrupt Practices Act (FCPA) enforcement actions regarding...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
Over the past 15 months the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) has made clear through three Foreign Corrupt Practices Act (FCPA) enforcement actions and speeches, their priorities in...more