Episode 331- NAVEX State of Risk and Compliance Programs
What the Board Should Be Asking About the Compliance Program
Common Scenarios Triggering False Claims Act Violations, Part 3: Claims and Investigations
Compliance into the Weeds: Of Fat Fingers, Internal Controls and Compliance
Vicky Hanks of Blake Morgan on Building an Effective Employee Brand - Passle's CMO Series Podcast
Better Investigative Interviewing
Hot Topics in International Trade
Episode 301 -- Steve Naughton on Compliance and Complaince Education at Loyola Law School Program
Episode 298 -- Electronics Communications Risks and Ephemeral Messaging
Episode 297 -- Susan Divers on LRN's 2023 Program Effectiveness Report
The Justice Insiders Podcast: SEC Plays Chicken with Jarkesy
JONES DAY TALKS®: The Evolution of Corporate Compliance Programs: Key Issues for Multinational Companies
Compliance & Disaster Preparedness
Compliance Series Part 3: Ensuring Compliance Programs are Effective
Compliance Programs Part 2: Designing a Successful Compliance Program
Compliance Programs Part 1: What is a Compliance Program and Why do Businesses Need One?
Law Firm ILN-telligence Podcast: Episode 73: Daniel García Piñeros, Gamboa, García & Cardona Abogados
Episode 284 -- How to Implement a Compliance Compensation System
Episode 276 -- Review of Phillips and Franks Int'l SEC FCPA Settlements
One Month to More Effective Internal Controls - Day 17 - COSO Objective IV: Information and Communication
In its proposed Plea Agreement, the Department of Justice (DOJ) lays out the abject failures of Boeing which led the DOJ to conclude the underlying Deferred Prosecution Agreement (DPA) from 2021 has been breached. The DOJ...more
When it comes to corporate accountability and the often murky waters of compliance, few cases are as illustrative and significant as the ongoing litigation involving Boeing. Since the 737 MAX safety scandal erupted in 2021,...more
Boeing’s Plea Agreement includes two Separate Factual Statements — the January 7, 2021 DPA, which is discussed in a prior blog post, and a factual outline of Boeing’s breach of the original DPA, resulting in the current Plea...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
Ericsson is having a tough time. First, in 2019, Ericsson settled FCPA charges with the Justice Department and the SEC for a total of $1 billion (with a B). Second, Ericsson had an independent compliance monitor appointed...more
Il y a presque cinq ans, la France a promulgué sa loi anti-corruption, dite loi Sapin II. Cette loi, considérée comme disruptive à l'époque, a introduit des innovations importantes, y compris la possibilité pour les...more
Almost five years ago, France enacted its anti-corruption legislation, Sapin II. The law was considered ground-breaking at the time and introduced a number of important innovations, including the ability for companies to be...more
I conclude my review of the Amec Foster Wheeler (Foster Wheeler) Foreign Corrupt Practices Act (FCPA) enforcement action. Today, I want to close with the result and some key lessons for the 2021 compliance professional. These...more
Beam Suntory, a global producer and distributor of distilled beverages, settled its FCPA case with DOJ for $19.5 million for bribes paid in India. The DOJ settlement follows an SEC FCPA settlement for $8 million announced...more
On 17 July 2020, a three-year Deferred Prosecution Agreement (DPA) between the Serious Fraud Office (SFO) and G4S Care & Justice Services (UK) Ltd (G4S) was approved. This DPA is the second arising from fraudulent conduct in...more
On December 6, 2019, Telefonaktiebolaget LM Ericsson (Ericsson or the Company), resolved long-running investigations by the U.S. Department of Justice (DOJ) and the U.S. Securities and Exchange Commission (SEC) into the...more
Last week the Justice Department (DOJ) announced a resolution of the long standing Foreign Corrupt Practices Act (FCPA) enforcement action involving Telefonaktiebolaget LM Ericsson (Ericsson), a multinational networking and...more
Just to repeat myself – pharmaceutical and medical device firms face extraordinary risks of enforcement under the False Claims Act. While everyone likes to write and focus on FCPA or anti-corruption risks for global drug and...more
On March 6, 2019, the Securities and Exchange Commission (“SEC”) announced that it was settling allegations that Russian telecommunications company Mobile Telesystems Pjsc (“MTS”) violated anti-bribery, books and records, and...more
We are in a five-part exploration of the recent the Department of Justice (DOJ) and Securities Exchange Commission (SEC) resolution of a Foreign Corrupt Practices Act (FCPA) enforcement action against the Russian telecom...more
This blog post concludes my multi-part exploration of the Petróleo Brasileiro S.A. – Petrobras (Petrobras) Foreign Corrupt Practices Act (FCPA) enforcement action. Today we consider the stunning result achieved by Petrobras –...more
Last week’s announcement by the Securities and Exchange Commission (SEC) of the resolution of its outstanding Foreign Corrupt Practices Act (FCPA) enforcement action with Halliburton Company continues to resonate and provide...more
A most “daring act” seems to be a good way to introduce a multi-part look at the recent Foreign Corrupt Practices Act (FCPA) enforcement action involving the Chilean chemicals and mining company Sociedad Química y Minera de...more
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
On December 9th, 2016, France officially enacted the Law on transparency, anti-corruption and economic modernization (so-called "Sapin II bill") which introduces the following key changes...more
The Embraer FCPA settlement action contains a number of important lessons learned and compliance reminders. In several significant respects, the Embraer case confirms in several areas why proactive compliance programs are...more
After years of investigation, disclosures, and press reports, the Embraer FCPA case finally came to a close. Hopefully, we will not see more of these long-term, seemingly endless investigations. The Justice Department and the...more
I conclude my exploration of the recently announced Department of Justice (DOJ) and Securities and Exchange Commission (SEC) Foreign Corrupt Practices Act (FCPA) enforcement action with the announcement of the resolution of...more
Today I continue my exploration of the recently announced Department of Justice (DOJ) and Securities and Exchange Commission (SEC) Foreign Corrupt Practices Act (FCPA) enforcement action with the announcement of the...more
The Justice Department and the Securities Exchange Commission delivered a powerful FCPA enforcement message to private equity and hedge funds. Och-Ziff settled with the DOJ and SEC for total penalties of $412 million....more