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TransPerfect Legal

Three Takeaways from the Mexico Summit on Anti-Corruption & Compliance

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Earlier this month at the ACI Mexico Summit on Anti-Corruption & Compliance, Foreign Corrupt Practices Act (FCPA) and compliance lawyers from across Latin America gathered in Mexico City for two days of thought leadership and...more

A&O Shearman

Top challenges for white collar crime and investigations lawyers in 2024

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We asked our global white collar crime team for their views on the key challenges in 2024 for in‑house investigations teams and white collar crime lawyers, and how to manage the associated risks. Here is what they said. ...more

Guidepost Solutions LLC

DOJ Maintains Interest in Bribery in Mexico and Latin America

Recent Department of Justice (“DOJ” or “Department”) activity on bribery in Mexico and Latin America sends a warning and provides a roadmap to companies doing business there.  By following the roadmap, companies may escape...more

Morrison & Foerster LLP

True Facts About False Claims: MoFo's FCA Newsletter - December 2024

Designed for busy in-house counsel and compliance professionals, this newsletter seeks to bring you up to speed on key federal and state False Claims Act (FCA) developments, with links to primary resources. Each quarter, we...more

The Volkov Law Group

Google’s Failure to Preserve Electronic Communications — A Warning to Every Company of a New Reality Surrounding Electronic Data

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One thing you can count on — change.  Not that there is anything wrong with that, but not to be too dramatic, we are at the precipice of some significant technology trends that will have a profound impact on corporate...more

Sheppard Mullin Richter & Hampton LLP

Recent Cyber-Related False Claims Act Activity Signals Contractors and Universities Should Examine Their Cybersecurity Practices...

In recent weeks, there has been an uptick in news of cyber-related False Claims Act (“FCA”) activity. For example, on September 1, 2023, the court unsealed a qui tam lawsuit against Penn State University relating to...more

Morrison & Foerster LLP

Deputy Attorney General Lisa Monaco Emphasizes Continued Focus on White Collar Crime Enforcement by the U.S. Department of Justice

The Department of Justice (“DOJ” or “Department”) has continued to make clear that white collar crime is a top priority of its enforcement efforts. On October 28, 2021, Deputy Attorney General (“DAG”) Lisa Monaco issued a...more

American Conference Institute (ACI)

[Virtual Event] 37th International Conference on the FCPA - December 2nd - 3rd, 9:00 am - 4:30 pm EST

The Annual Gathering for the Global Anti-Corruption Community - Exclusive Interview with President of Microsoft at FCPA DC - The world has reached an inflection point in which digital technology is being used as both a...more

Ballard Spahr LLP

Consumer lender sets aside $21.7 million to settle Foreign Corrupt Practices Act probe

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South Carolina-based consumer lender World Acceptance Corporation announced recently that it had earmarked $21.7 million to resolve a Securities and Exchange Commission (SEC) probe into its compliance with the Foreign Corrupt...more

Skadden, Arps, Slate, Meagher & Flom LLP

A Dialogue With Corporate Counsel: Skadden’s Eighth Annual Pharmaceutical and Medical Device Seminar

On October 30, 2018, Skadden hosted its Eighth Annual Pharmaceutical and Medical Device Enforcement and Litigation Seminar in New York City, which focused on U.S. enforcement issues faced by companies throughout the industry....more

Holland & Knight LLP

Petrobras Agrees to Pay More Than $1.8 Billion for Facilitating FCPA Violations

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• Four years ago, Brazilian authorities began Operation Car Wash, a wide-ranging and still ongoing corruption and money laundering investigation that has spanned 11 countries. • The fallout continues with a recent U.S....more

Thomas Fox - Compliance Evangelist

Day 29 of 31 Days to a More Effective Compliance Program

One new and different item was laid out in the Evaluation of Corporate Compliance Program, supplementing the Ten Hallmarks of an Effective Compliance Program from the 2012 FCPA Guidance. This was the performance of a root...more

Thomas Fox - Compliance Evangelist

A Chief Compliance Officer's Guide to Investigations

Tom Fox in conversation with Jonathan Marks, who has laid out a concrete way for CCOs and c-level executives to think through how to plan an investigation, staff it properly and meet the inevitable challenges. ...more

Thomas Fox - Compliance Evangelist

Day 8 of One Month to Better Investigations and Reporting Day 8-Preparing for the Investigation

Properly Scoped Investigation by Qualified Personnel – How has the company ensured that the investigations have been properly scoped, and were independent, objective, appropriately conducted, and properly documented? These...more

Thomas Fox - Compliance Evangelist

Day 7 of One Month to Better Investigations and Report-How Investigations Inform Remediation

There is nothing like an internal whistleblower report about a FCPA violation, the finding of such an issue or (even worse) a subpoena from the DOJ to trigger the Board of Directors and senior management attention to the...more

Thomas Fox - Compliance Evangelist

Day 5 of One Month to Better Investigations and Reporting-the Board’s Investigation Protocol

Many companies have an investigation protocol in place when a potential Foreign Corruption Practices Act (FCPA) or other legal issue arises? However, many Boards of Directors do not have the same rigor when it comes to an...more

Thomas Fox - Compliance Evangelist

Day 4 Of One Month To Better Investigations And Reporting-Triage Of Allegations

One of the things that I learned from the television series M*A*S*H was the need for triage. In the hospital setting, triage is the process of determining the priority of patients’ treatments based on the severity of their...more

Thomas Fox - Compliance Evangelist

Day 3 of One Month to Better Investigations and Reporting-the Investigation Protocol

Your company should have a detailed written procedure for handling any complaint or allegation of bribery or corruption, regardless of the means through which it is communicated. The mechanism could include the internal...more

Thomas Fox - Compliance Evangelist

Day 2 of One Month to Better Investigations and Reporting-Selection of Investigative Counsel

A key component of this fair and objective evaluation is the WHO question; that is, who should supervise the investigation and who should handle the investigation? You should have independent counsel should handle any serious...more

Thomas Fox - Compliance Evangelist

Day 1 of One Month to Better Investigations and Reporting-Introduction to Investigations and Internal Reporting

The call, email or tip comes into your office; an employee reports suspicious activity somewhere across the globe. That activity might well turn into a Foreign Corrupt Practices Act (FCPA) issue for your company. As the Chief...more

Jones Day

Department of Justice Fraud Section Provides Guidance on Evaluating Corporate Compliance Programs

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On February 8, 2017, the United States Department of Justice ("DOJ") Fraud Section published a blueprint for assessing corporate compliance efforts, titled "Evaluation of Corporate Compliance Programs" ("Guidance"). It...more

Troutman Pepper

Lessons Learned from the FCPA Pilot Program's First Six Months

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The guidance issued by the DOJ in connection with the Pilot Program and recent declinations state that disclosure, remediation and cooperation are essential to any favorable resolution with the government. Six months...more

Foley & Lardner LLP

DOJ Fraud Section Offers Super Credit in FCPA Pilot Program

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This week, the Fraud Section of the Department of Justice (DOJ) announced a pilot program that extends additional “mitigation credit” to qualifying companies that “fully cooperate” in matters involving the Foreign Corrupt...more

Dorsey & Whitney LLP

Travel, Entertainment, Gifts Yield DOJ, SEC FCPA Charges Again

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Travel, entertainment and gifts tied to inadequate controls are recurrent themes in FCPA cases. Many of these cases involve the use of agents and center in China. Each of these recurrent items appear in the most recent FCPA...more

Thomas Fox - Compliance Evangelist

Episode 155-Mara Senn on FCPA Investigations and the Decision to Self-Disclose

In this episode I visit with Mara Senn, a partner at Arnold & Porter on how to think through a FCPA investigation and she provides a decision making calculus on how to make a decision...more

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