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Foreign Official Foreign Corrupt Practices Act (FCPA) Corporate Counsel

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for July 2024

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

ArentFox Schiff

How to Avoid an Independent Compliance Monitor: Lessons From the SAP Settlement

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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

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for August 2023

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

Womble Bond Dickinson

Handle with Care: FCPA Travel & Hospitality Expenses

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Two recent Foreign Corrupt Practices Act (FCPA) actions – a Department of Justice (DOJ) Opinion letter and an SEC settlement – underscore key diligence questions that legal and compliance departments should address when...more

Miller Canfield

Record Level of FCPA Enforcement in 2020 Highlights Key Risk Areas

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The year 2020 witnessed a record level of $2.78 billion in corporate fines and penalties from enforcement of the Foreign Corrupt Practices Act (FCPA) by the U.S. Department of Justice (DOJ) and the U.S. Securities and...more

Foley Hoag LLP

Foreign Executive’s FCPA Convictions Overturned

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District Court Finds Insufficient Evidence That He Acted As Agent of U.S. Subsidiary - Background - On February 26, 2020, a federal judge in Connecticut granted in part the motion for acquittal of a former senior executive...more

The Volkov Law Group

Three Former Executives from Alstom and Marubeni Charged with Criminal FCPA Violations in Indonesia

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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

WilmerHale

$1 Billion Ericsson Resolution, Three Jury Verdicts Cap Off Busy Fourth Quarter for US FCPA Enforcement

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On December 6, 2019, the Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) agreed to resolve allegations that multinational telecommunications company Telefonaktiebolaget LM Ericsson (Ericsson or...more

The Volkov Law Group

Barclays Agrees to Pay the SEC $6.3 Million to Settle FCPA Offenses for Hiring of Relatives of Foreign Officials in Asia

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Barclays joined the club of global financial institutions settling FCPA violations for hiring of relatives of foreign officials in Asia.  Barclays agreed to disgorge $3.8 million and paid prejudgment interest of nearly $1...more

WilmerHale

Juniper FCPA Settlement Provides Useful Compliance Reminders

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On August 29, 2019, the Securities and Exchange Commission (“Commission” or “SEC”) agreed to resolve an enforcement action against Juniper Networks, Inc. (“Juniper” or the “Company”), a Silicon Valley-based cybersecurity and...more

McDermott Will & Emery

Second Circuit Declines to Limit FCPA's Scope

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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

Eversheds Sutherland (US) LLP

The Second Circuit holds “Official Act” not required for FCPA cases 

On August 9, 2019, the US Court of Appeals for the Second Circuit upheld a Chinese real estate developer’s conviction in United States v. Ng Lap Seng. The Court rejected defendant’s attempt to read an “official act”...more

Wilson Sonsini Goodrich & Rosati

Telefônica Brasil Case Reinforces Risks of Gifts and Hospitality Involving Foreign Officials

On May 9, 2019, Telefônica Brasil agreed to pay a US$4.13 million civil fine to settle U.S. Securities and Exchange Commission charges for violations of the internal accounting controls and recordkeeping provisions of the...more

Jones Day

Anti-Corruption Regulation Survey of 41 Countries 2017–2018

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Welcome to the 2017-2018 edition of the Jones Day Anti-Corruption Regulation Survey. In 2017 and 2018 to date, there has continued to be an increasing awareness among multinational companies of the significance of...more

BakerHostetler

Foreign Corrupt Practices Act 2017 Year-End Update

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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

Bennett Jones LLP

What Canadian Companies Need to Know About Effective Compliance with Canadian, U.S. and Global Anti-Corruption Laws

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Issue-Spotting and Compliance Best Practices - An understanding of the Foreign Corrupt Practices Act (FCPA) and Corruption of Foreign Public Officials Act (CFPOA) provides a framework to consider how, when and why these...more

The Volkov Law Group

Justice Department Closes Out 2017 with 2 FCPA Actions: Keppel Offshore and Marine and Embraer Individual

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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

The Volkov Law Group

The FCPA Week That Was — Seven Individuals Charged for FCPA Violations

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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

Thomas Fox - Compliance Evangelist

Rolls-Royce Global Enforcement Action: Part I

When most people across the globe think of Rolls-Royce, one word comes to mind – excellence. Yet that image largely relates to Rolls-Royce Limited, the automobile manufacturer, which was founded in 1909. Just a few years...more

A&O Shearman

Shearman & Sterling’s Recent Trends and Patterns in the Enforcement of the Foreign Corrupt Practices Act (FCPA)/FCPA Digest -...

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Shearman & Sterling’s bi-annual Trends & Patterns in FCPA Enforcement report provides insightful analysis of recent enforcement trends and patterns in the US, the UK and elsewhere, as well as helpful guidance on emerging best...more

The Volkov Law Group

Lessons Learned From FCPA Enforcement Against JP Morgan for Sons and Daughters Referral Program

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Last week, the Justice Department and the SEC finally brought to a close the Sons and Daughters or Princelings investigation. Pending investigations against four other companies still remain to be resolved....more

BCLP

Recent SEC Settlement Demonstrates FCPA Risks from Charitable Contributions

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For just the second time in the Foreign Corrupt Practices Act’s (FCPA) history, a company was charged with FCPA offenses based solely on a charitable contribution that was intended to buy the influence of a foreign official. ...more

Bracewell LLP

Improved U.S. - Cuba Relations Create Potential FCPA Risks for U.S. Companies Looking to Do Business There

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The normalization of relations between the United States and Cuba offers potential lucrative business opportunities for companies that are prepared to meet Cuba’s unique corruption risks. On December 17, 2014, President...more

The Volkov Law Group

Doing Business in China Should Be “Scary”

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Lauren Connell, Managing Associate at The Volkov Law Group, joins us again for another posting on corruption risks in China. A little fear is healthy. It will keep you vigilant and aware. At this point if corporate...more

BCLP

SEC Targets Insufficient Anti-Corruption Compliance Programs

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The Securities and Exchange Commission’s (SEC) recent Foreign Corrupt Practices Act (FCPA) settlements focus on companies’ lack of sufficient anti-corruption compliance programs, which means, to the SEC, that the companies...more

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