Compliance into the Weeds: Understanding the Telefonica Venezuela FCPA Enforcement Action
Episode 344 -- SEC Settles FCPA Case with Moog for $1.7 Million
Wicked Coin: FIFA: Soccer, Scandal, and Sportswashing
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
What happened? On September 10, the SEC announced that John Deere agreed to pay almost $10 million to resolve allegations it had violated the FCPA. The SEC alleged that Wirtgen Thailand, an indirect subsidiary of John Deere,...more
The Justice Department is encouraging companies to voluntarily disclose criminal violations — “Come in and confess” and DOJ offers promises of a declination. But even a declination comes with a requirement — the company has...more
In a recent blockbuster FCPA settlement, DOJ announced a $661 million resolution with Gunvor, one of the world’s largest commodities trading companies. DOJ’s settlement represents a “return” to its long-standing aggressive...more
As always, I tend to repeat myself. However, one important point needs to be repeated — DOJ is in the midst of launching an aggressive sanctions and export control program against corporations and individuals. DOJ has...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
Life is always filled with surprises. Just when we thought 2023 was a “slow” FCPA enforcement year, DOJ and SEC announced a large enforcement action against SAP for approximately $220 million for FCPA violations in South...more
We continue our exploration of the Foreign Corrupt Practices Act (FCPA) enforcement involving the German software company, SAP. The company agreed to pay the Department of Justice (DOJ) and Securities and Exchange Commission...more
Albemarle’s bribery schemes look and sound like text-book examples of third-party agents being paid high commissions as a way to funnel bribery payments to foreign officials at state-owned oil refineries. However, as usual,...more
The past few weeks have not been kind to 3M. The company recently settled with the SEC for $6.5 million to resolve alleged FCPA violations related to its Chinese subsidiary’s dealings with Chinese state-owned healthcare...more
The SEC has been racking up several FCPA enforcement actions. DOJ appears to be declining many of these cases. The division of enforcement appeared to follow a pattern – on larger cases with more pervasive violations, DOJ...more
In its first enforcement action of 2023, the Justice Department charged a Connecticut man and a foreign national with FCPA bribery and money laundering charges stemming from a bribery scheme to secure contracts with Petrobras...more
Talk about a reminder of the past, Asante Berko, a former Executive Director in Goldman Sachs, recently was arrested in London on criminal FCPA charges arising from his involvement in a bribery scheme in Ghana....more
The Second Circuit has made the government’s formerly straightforward task of assigning vicarious liability to a corporate principal under the Foreign Corrupt Practices Act considerably harder. Our White Collar, Government &...more
We asked our global white collar crime team for their views on key challenges in 2022 for in house investigations teams and white collar crime lawyers, and how to manage the associated risks. Here are the top ten....more
Compliance into the Weeds is the only weekly podcast that takes a deep dive into a Compliance-related topic, literally going into the weeds to more fully explore a subject. On Tuesday, Matt and I began a special two-part...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
On November 25th, the OECD Council for Further Combating Bribery of Foreign Public Officials in International Business Transactions adopted a series of recommendations for member countries to implement, in an effort to curb...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 case developments from the past month,...more
Enforcement authorities throughout the Americas continued investigations of fraud, corruption, and other misconduct across the region. Below are some of the highlights of the last quarter. ...more
Three weeks into the Biden Administration, businesses must prepare for significant changes in regulatory and enforcement priorities. Our White Collar, Government & Internal Investigations Team summarizes the new...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
A federal grand jury in the Eastern District of New York returned an indictment against Javier Aguilar, an oil trader at Vitol, an energy and commodity trading company, for his role in a five-year international bribery and...more
In 1977, the United States enacted the Foreign Corrupt Practices Act (FCPA). The FCPA prohibits an offer, payment, promise or the authorization of a payment of money or anything of value (a/k/a bribery) to a foreign official...more