Are You a Foreign Agent? [More with McGlinchey, Ep. 21
Much has been said about the Foreign Extortion Prevention Act (“FEPA”) that President Biden signed into the law in December 2023, with particular attention given to the corrupt foreign officials who seek bribes from...more
You can always learn a lot from reviewing the underlying conduct to an FCPA enforcement action. Chief compliance officers can identify specific risk factors, mitigation steps and root causes for bribery schemes. ...more
On September 29, 2022, the Financial Crimes Enforcement Network (“FinCEN”) issued a final rule (the “Rule”), the first of three planned rulemakings implementing the beneficial ownership information reporting rules of the...more
On October 6, 2022, the Federal Communications Commission (FCC or Commission) released a Second Notice of Proposed Rulemaking (Second NPRM) in which the Commission proposed to amend its rules for the identification of foreign...more
Even with the absence of any major DOJ FCPA enforcement actions, DOJ issued an interesting FCPA Opinion Letter last week addressing application of the FCPA in circumstances where organizations face imminent serious bodily...more
While GDP and worldwide economies shrink under the continuing impact of COVID-19, government budgets have expanded to support healthcare responses to the pandemic and social-welfare in response to growing unemployment and...more
On July 3, 2020, the Department of Justice (“DOJ”) and Securities and Exchange Commission (“SEC”) updated their 2012 joint guidance on the Foreign Corrupt Practices Act (“FCPA”) in the SEC and DOJ’s FCPA Resource Guide...more
As discussed in a previous alert dated June 18, 2019, the U.S. Department of Education (the “Department”) over the last year increased its scrutiny of postsecondary institutions’ contracts with, and gifts from, foreign...more