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
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
In March 2024, the Department of Justice (DOJ) announced the resolution of a Foreign Corrupt Practices Act (FCPA) enforcement action involving the Swiss trading firm G Trafigura Beheer B.V. (Trafigura), an international...more
Due diligence is generally recognized in three levels: Level I, Level II and Level III. Each level is appropriate for a different level of corruption risk. The key is to develop a mechanism to determine the appropriate level...more
On October 5, 2023, Deputy Attorney General, Lisa Monaco, announced a new safe harbor policy for voluntary self-disclosures made in the mergers and acquisitions context. The safe harbor policy will apply Department-wide and...more
On December 14, the Department of Justice (DOJ) announced that Freepoint Commodities LLC, a Connecticut-based commodities trader, had agreed to a three-year deferred prosecution agreement (DPA) to resolve a DOJ investigation...more
In September 2022, Deputy Attorney General Lisa Monaco outlined the Department of Justice (DOJ) approach to enforcing corporate misconduct and directed agencies to review existing voluntary self-disclosure policies or, if...more
Currently there is a patchwork of anticorruption laws across the EU. What has been lacking, though, is a EU-wide approach. That is likely to change soon, reports Vera Cherepanova, founding partner of Studio Etica. Change is...more
Early in October at the 2023 SCCE Compliance and Ethics Institute, Deputy Attorney General Lisa Monaco delivered a long-anticipated speech expanding and formalizing the Department of Justice’s (DOJ’s) new Safe Harbor for...more
I recently had the opportunity to visit with, Chris Mason, VP Global Compliance & Investigations at Infortal Worldwide and Dr. Ian Oxnevad, Director, Geopolitical Risk at Infortal Worldwide for a sponsor podcast on Infortal...more
The Department of Justice has been relatively quiet this year in bringing corporate FCPA enforcement actions and settlements. Aside from the Ericsson breach of its Deferred Prosecution Agreement, the Corficocolombiana...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
Let’s move beyond the headline – trade compliance is the new FCPA. We get it. The next step is to do something about it. The Justice Department has repeated this refrain – it is one of its greatest hits. In addition, DOJ,...more
A recently re-introduced bill by Senator Marco Rubio (R-FL) would seek to expand the reach of the Foreign Corrupt Practices Act (“FCPA”) over corporations operating in China...more
On January 17, 2023, Assistant Attorney General (AAG) Kenneth Polite, Jr. announced updates to the Foreign Corrupt Practices Act (FCPA) Corporate Enforcement Policy. Since the inception of the FCPA Corporate Enforcement...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
Hosted by American Conference Institute, the Mexico Summit on Anti-Corruption & Compliance Programs returns for another exciting year with curated programming that shines a global spotlight on anti-corruption compliance...more
At a September 15, 2022, speech at New York University School of Law, US Deputy Attorney General (Deputy AG) Lisa Monaco announced several new policies intended to further the aggressive stance the US Department of Justice...more
Deputy Attorney General (DAG) Lisa Monaco announced several significant policy updates affecting the U.S. Department of Justice’s (DOJ) enforcement practices for both corporations and individuals on September 15, 2022...more
FCPA (Foreign Corrupt Practices Act) compliance ought to be at the forefront of companies of all sizes in all industries. Due to the globalization of company operations, as well as bribes paid to foreign officials ...more
The new DOJ Certification requirements certainly raise a number of new issues and risks for senior management and chief compliance officers. In Part I of this series, I outlined the specific language and the Plea Agreement...more
The U.S. Department of Justice ("DOJ") is making it harder on companies that commit corporate crimes. A lot harder. That’s the message that Deputy Attorney General Lisa Monaco recently gave attendees at the American Bar...more
On October 28, 2021, Deputy Attorney General Lisa Monaco addressed the ABA’s National Institute on White Collar Crime, in which she made clear that monitorships are back on the menu as a means of ensuring corporate...more
Ethics and compliance professionals believe in their mission – if they did not, they would not be in the field. E&C professionals believe in the power of positive thinking, ethical conduct, and in the overall ability of an...more
Over the course of the year — and even dating back to his time on the campaign trail — President Biden and senior officials in his administration, including Department of Justice (DOJ) and Security and Exchange Commission...more
“The truest measure of an effective compliance program is how it responds to misconduct.”— FCPA Guidance (2d. ed 2020) - This straight-forward statement (above) of a company’s commitment to its “effective” compliance...more