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
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
Signed into law on December 22, 2023, the Foreign Extortion Prevention Act (FEPA) signals a further focus by the U.S. government on anti-corruption enforcement. Our White Collar, Government & Internal Investigations Team...more
The Albemarle FCPA enforcement action was announced at a good time. This year has been a slow year for DOJ’s FCPA enforcement program, although there are several months before the end of the year. The SEC, on the other hand,...more
Last week, I began a multi-part exploration of one world’s largest anti-corruption enforcement actions, the J&F Investimentos SA (J&F) matter. It involved huge fines and penalties in both Brazil and the United States. Of...more
We rarely have seen a single Foreign Corrupt Practices Act (FCPA) enforcement action generate so many individual criminal pleas. The Sargeant Marine Inc. (Sargeant Marine) case is an exception. To date, there have been six...more
In its continuing aggressive FCPA criminal enforcement program, DOJ announced the indictment of two former Alstom executives and a former Marubeni executive with FCPA violations arising from a bribery scheme in Indonesia....more
Almost every FCPA enforcement action contains important lessons learned in unraveling a bribery scheme. Airbus has three broad divisions: (1) Commercial Division; (2) Defense & Space Division; and (3) Helicopters...more
La Ley de Prácticas Corruptas en el Extranjero (“Foreign Corrupt Practices Act – FCPA”) prohíbe el pago de sobornos a funcionarios extranjeros para ayudar a obtener o retener negocios. Exige que las empresas cuyos valores se...more
The Foreign Corrupt Practices Act (FCPA) prohibits payment of bribes to foreign officials to assist with obtaining or retaining business. It requires companies whose securities are listed in the US to maintain books and...more
The Second Circuit’s decision in United States v. Ng Lap Seng is a win for the government, because it reinforces the broad reach and scope of the Justice Department’s enforcement of the FCPA. When adopting and implementing an...more
Last week, a grand jury in the Southern District of Florida indicted two former Venezuelan officials, charging them with seven counts of money laundering and one count of money-laundering conspiracy. The charges relate to...more
The MTS FCPA enforcement action stands as one of several significant prosecutions in FCPA history. The breadth and depth of MTS’ corruption scheme stands as another example of systemic bribery cultures. The details of the...more
The MTS bribery scandal in Uzbekistan represents the culmination of several significant FCPA violations involving VimpelCom, Telia Sonera, MTS, and Gulnara Karimova, the notoriously corrupt daughter of the former Uzbek...more
Conspiracy and Aiding-and-Abetting Charges Cannot Expand Territorial Reach of the FCPA to a Non-US Defendant Who Otherwise Would Not Be Liable for His Ex-US Conduct - United States v. Hoskins, US Court of Appeals for the...more
Companies have definitely matured in the development and implementation of their ethics and compliance programs. Whether the pace has been rapid enough or is too slow, that is a debatable issue. A good litmus test for a...more
When you read through the United Technologies SEC FCPA enforcement action, you cannot help but shake your head – the level of abuse and participation by senior managers in the UT companies – Pratt & Whitney and Otis Elevator...more
Despite the fact that the Foreign Corrupt Practices Act has been in force for decades there is relatively little case law interpreting its provisions. A great deal of the existing interpretation of the Act stems from...more
Last week Credit Suisse Group AG (CSAG) and Credit Suisse (Hong Kong) Limited (CSHK), a subsidiary of CSAFG, settled a Foreign Corrupt Practices Act (FCPA) enforcement action for just over $77 million for the illegal hiring...more
In a win for transparency, the rule of law and the international fight against bribery and corruption, the Department of Justice (DOJ) secured a victory in all three categories with the sentencing of Egbert Yvan Ferdinand...more
Anti-Corruption enforcement is a top priority in France, the UK, and the US. Each of these countries has armed its enforcers with the enforcement tools necessary to investigate and prosecute corporations and individuals. Join...more
2017 marked the fortieth anniversary of the Foreign Corrupt Practices Act (FCPA), and showed continued robust enforcement against both individuals and companies by the U.S. Department of Justice (DOJ) and the U.S. Securities...more
The Department of Justice finished 2017 with two significant FCPA enforcement actions, and fittingly, one was a corporate settlement and another was an individual criminal guilty plea. The Justice Department’s final FCPA...more
At the 34th International Conference on the Foreign Corrupt Practices Act held last week in Washington, D.C., industry executives, members of the defense bar, and regulators examined developments in the enforcement of the...more
To all the “nattering nabobs of negativity” concerning FCPA enforcement, the US Justice Department responded with a resounding message – not only is FCPA enforcement here to stay, but individual violators are on DOJ’s radar...more
The single most frequently asked question by our international clients over the past several months is whether there will be changes in white collar prosecution priorities under the new administration, specifically with...more