Episode 116 -- Alstom Executive Convicted of FCPA and Money Laundering Offenses
FCPA Compliance and Ethics Report-Episode 165-BHP FCPA Enforcement and Lessons Learned for the Compliance Practitioner
Bribery & Corruption in the Military. A Front-Line View (Part II)
FCPA Compliance and Ethics Report-Episode 130, The Oscars and Compliance, Part IV with Jay Rosen
FCPA Compliance and Ethics Report-Episode 122-with Matt Kelly on Alstom, Avon and Petrobras
FCPA Compliance and Ethics Report-Episode 121-FCPA Year in Review, Part II
Thinking Compliance When Protecting Your Ideas Internationally
FCPA Compliance and Ethics Report-Episode 66-Visit with the FCPA Professor
Fine Tuning Your Anti Corruption Compliance Program
The FCPA Compliance and Ethics Report, Episode 3
President Trump’s recent Executive Order (EO), which seeks to reduce enforcement of the anti-bribery and anti-corruption provisions of the Foreign Corrupt Practices Act (“FCPA”), may be perceived as a declaration of an...more
In Samantar v. Yousuf, the US Supreme Court held that foreign officials, when sued in their individual capacity, are subject to immunity under a similar, but different set of rules that govern lawsuits against foreign states....more
One of the most notable developments in the anti-corruption world is the Trump Administration’s Feb. 10 Executive Order, “Pausing Foreign Corrupt Practices Act Enforcement To Further American Economic and National Security.” ...more
The landscape of criminal prosecution of foreign bribery has shifted, and the second Trump administration has made its priorities clear; however, companies still have 950 million reasons and counting to strengthen their...more
On February 10, 2025, President Trump issued a new Executive Order (“EO”) titled “Pausing Foreign Corrupt Practice Act Enforcement to Further American Economic and National Security.” This EO comes on the tail of Attorney...more
Australia has a zero-tolerance approach to corruption, and this policy knows no border or nationality. Bribery or attempts to bribe foreign public officials are considered severe crimes, as mentioned in division 70 of the...more
In December 2023, US Congress passed a landmark anti-bribery law: the Foreign Extortion Prevention Act (FEPA). FEPA was designed to supplement the Foreign Corrupt Practices Act (FCPA) and expand liability to foreign...more
Two recent court Foreign Corrupt Practices Act (FCPA) cases, a significant amendment to the Foreign Extortion Prevention Act (FEPA), and the new pilot whistleblower rewards program show that Anti-Corruption 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
On May 6, 2024, the U.S. Department of the Treasury (Treasury) and Internal Revenue Service (IRS) published final regulations (Final Regulations) regarding clean vehicle tax credits under Internal Revenue Code sections 25E...more
The sentencing of Romy Andrianarisoa, the first ever foreign public official to be convicted under the Bribery Act 2010, provides important takeaways. On 10 May 2024, Romy Andrianarisoa was sentenced to three-and-a-half...more
Building on the recent passage of the Foreign Extortion Prevention Act (FEPA), at the American Bar Association’s 2024 National Institute on White Collar Crime conference in San Francisco earlier this month (2024 ABA...more
According to the terms of a superseding information made public by the U.S. Attorney’s Office for the Southern District of New York on or about February 13, 2024, Mauricio Gomez Baez (“Baez”)—a former Stericycle executive for...more
FEPA contains a broad prohibition on corrupt activity and applies to a broad category of public officials. First, FEPA makes it unlawful for any foreign official to “demand, seek, receive, accept, or agree to” receive...more
As we look back on the anti-corruption enforcement trends we saw in 2023, there were several key developments. The Department of Justice (“DOJ”) brought 11 enforcement actions in 2023. Only six were against companies -...more
On December 22, 2023, President Biden completed the proverbial “sandwich” against international bribery schemes by signing the groundbreaking Foreign Extortion Prevention Act (“FEPA”) into law....more
U.S. companies that do business globally may need to update their compliance training to ensure employees operating in international venues understand new risks. For decades, the Foreign Corrupt Practices Act has made it...more
President Biden recently signed into law the Foreign Extortion Prevention Act (“FEPA”), enabling federal prosecution of non-U.S. government officials who solicit or receive bribes. FEPA complements the Foreign Corrupt...more
After years of anticipation, President Biden signed the Foreign Extortion Prevention Act (FEPA) into law on December 22, 2023, ushering in a new era of international anti-corruption prosecution. The FEPA will make it easier...more
On December 22, 2023, President Biden signed into law the 2024 National Defense Authorization Act. This bipartisan legislation included the Foreign Extortion Prevention Act (FEPA), which enables criminal prosecution of...more
This week, SAP SE (SAP), the German-based software company, agreed to pay over $200 million to resolve investigations by the US Department of Justice (DOJ) and US Securities and Exchange Commission (SEC) into violations of...more
On December 22, 2023, President Biden signed the Foreign Extortion Prevention Act (FEPA) into law, revising Section 201 of Title 18 of the U.S. Code concerning bribery of government officials. This significant development...more
On December 22, 2023, President Biden signed into law the Foreign Extortion Prevention Act (FEPA) as part of the fiscal year 2024 National Defense Authorization Act. FEPA criminalizes demand-side bribery by foreign officials...more
On December 14, 2023, Congress passed the Foreign Extortion Prevention Act (“FEPA”) in an effort to address certain deficiencies inherent in the current iteration of the Foreign Corrupt Practices Act (“FCPA”), as part of the...more
Adding to federal prosecutors’ tool kit in fighting global corruption, on December 14, 2023, Congress passed with bipartisan support, the Foreign Extortion Prevention Act (FEPA). As part of the National Defense Authorization...more