Episode 339: Four Sanctions Cases Everyone Should Know
Episode 338 -- Deep Dive into the Deere SEC FCPA Case
FCPA Survival Guide - Step 8 - Investing in Compliance
Episode 328 -- Sanctions Enforcement Risks and Redlines
FCPA Survival Guide: Step 3 - Extensive Remediation
Episode 324 -- Third-Party Risks and Sanctions Compliance
Compliance Tip of the Day – Compliance Lessons from the Albemarle FCPA Enforcement Action
FCPA Survival Guide: Step 1 - Self-Disclosure
All Things Investigations: Compliance Lessons from Gunvor and Trafigura Enforcement Actions
Corruption, Crime & Compliance: Deep Dive into The Trafigura FCPA Settlement
Episode 317 -- A Deep Dive into the Trafigura FCPA Settlement
What's Going on with FCPA?
Episode 316 -- DOJ Announces New Whistleblower Policy
Compliance into The Weeds: Trafigura FCPA Enforcement Action
Corruption, Crime & Compliance: Deep Dive into The Gunvor FCPA Settlement
Episode 314 -- A Deep Dive into Gunvor's FCPA Settlement
Corruption, Crime & Compliance: DOJ’s Shifting Approach to Recidivism and Self-Disclosure
Episode 311 -- Tom Fox on FCPA Enforcement: Self Disclosure and Recidivism
Episode 307 -- Sanctions Enforcement Review and Predictions for 2024
Episode 305 -- Deep Dive into SAP FCPA Settlement
In her remarks to the American Bar Association’s National Institute on White Collar Crime, Deputy Attorney General (DAG) Lisa Monaco outlined the forthcoming whistleblower program that seeks to fill in the gaps of existing...more
The U.S. Department of Justice’s (“DOJ”) Criminal Division announced its new Corporate Whistleblower Awards Pilot Program on August 1, 2024. The Pilot Program incentivizes whistleblowers to provide information to the DOJ so...more
On March 7, 2024, Deputy Attorney General Lisa Monaco announced the Department of Justice (DOJ) would release a new whistleblower rewards program for civil and criminal forfeitures. On August 1, 2024, DOJ did just that—as the...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
For years, Department of Justice officials have stressed how important chief compliance officers are as the first line of defense in fighting corporate crimes. While that’s true, compliance programs now have a competitor in...more
Last week Deputy Attorney General Lisa Monaco announced that the U.S. Department of Justice (DOJ) will soon begin a pilot program to reward whistleblowers who alert prosecutors to significant corporate misconduct. The goal of...more
Recent legislative developments in the United Kingdom, public remarks from the new director of the UK Serious Fraud Office (SFO), and recent parliamentary hearings on the Post Office Horizon scandal put a spotlight on...more
On March 7, 2024, Deputy Attorney General Lisa Monaco said that the U.S. Department of Justice (DOJ) will test out a program to pay whistleblowers if they provide information on serious financial crimes and foreign and...more
At last week’s ABA National White Collar Crime Institute, the leadership of the Department of Justice (the DOJ or the Department), including Attorney General Merrick Garland and Deputy Attorney General Lisa Monaco, made clear...more
The more things change, the more things stay the same. For years, U.S. Department of Justice (DOJ) leadership has used the ABA National Institute on White Collar Crime and other major conferences to highlight enforcement...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
2023 was a banner year in the sanctions space and regulators seem primed to continue that performance in 2024. In December 2023, numerous government officials and industry experts convened at the New York Forum on Economic...more
The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency, specifically focusing on:...more
In 2022, the DOJ and the SEC resolved a total of ten corporate enforcement actions under the FCPA, more than double the number in the previous year. While the average corporate penalties only slightly increased to $168...more
For more than two years now, heads of the U.S. Department of Justice have maintained a steady drumbeat that they expect companies today to have in place a sound data analytics compliance program to proactively mitigate risks....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
Deputy Attorney General (DAG) Lisa Monaco’s September 15, 2022, memorandum on revisions to the Department of Justice’s (DOJ) Corporate Enforcement Policies (the Monaco Memo) reflects that preservation of business...more
Text messaging is convenient. It is an informal and instant mode of communication now available through numerous apps, which allow an individual to use their synced phone, tablet, and computer to quickly fire off messages. ...more
Users of ephemeral messaging applications may intend that their messages be—as the word “ephemeral” suggests—short lived, but the real-world consequences and legal ramifications from improper use of such apps can be anything...more
Last week, the Attorney General and a host of other Department of Justice (DOJ) officials announced the settlement of a massive Foreign Corrupt Practices Act (FCPA) and market manipulation case against Glencore plc...more
On March 3, 2022, at the 37th Annual American Bar Association Criminal Justice Section National Institute on White Collar Crime in San Francisco, Attorney General Merrick B. Garland emphasized that “the prosecution of...more
On December 17, 2021, a financial institution agreed to pay $200 million in fines to the Securities and Exchange Commission and Commodities Futures Trading Commission for allowing employees to discuss business on their...more
We begin the week before Christmas by looking at one heck of a compliance failure (or perhaps series of compliance failures) which led JPMorgan Chase Bank, NA, J.P. Morgan Securities LLC, and J.P. Morgan Securities plc...more
This is the third in our First 100 Days series examining important trends in white collar law and investigations in the early days of the Biden administration. Our previous entry discussed sanctions and export control trends....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