News & Analysis as of October 19, 2024

Compliance

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The Strategic Enforcement Plan (SEP) is a strategy developed by the United States Equal Employment Opportunity Commission which 1) establishes priorities for the EEOC and 2) integrates the EEOC's private and public enforcement efforts. The purpose of the SEP is to focus the EEOC's resources to best address discriminatory practices in the workplace. less -

The importance of explaining why

Society of Corporate Compliance and Ethics... on 7/15/2024

Writing, implementing, and enforcing strong compliance-related policies is critical to any compliance and ethics program. So, why do so many compliance failures occur due to breakdowns in internal controls?...more

New nationwide policy marks latest DOJ effort to incentivize voluntary self-disclosure

Eversheds Sutherland (US) LLP on 3/1/2023

On February 22, 2023, the US Department of Justice issued a nationwide policy for all US Attorney’s Offices (USAOs) outlining the circumstances in which a company may receive credit for voluntary self-disclosure (VSD)....more

The Role of Compliance in Government Enforcement

WilmerHale on 11/20/2020

As recent developments in corporate enforcement indicate, the United States Department of Justice (DOJ) continues to emphasize transparency, cooperation, and the importance of a strong compliance program. Enforcement trends...more

Leading Federal Officials Offer Advice on How Corporations Can Minimize Law Enforcement Risk

Holland & Knight LLP on 12/5/2019

Holland & Knight, the Florida Chamber of Commerce and the Miami-Dade Beacon Council hosted the Second Annual Florida Enforcement Summit on Nov. 20, 2019. The half-day program focused on informing the business community how to...more

Foreign Corrupt Practices Act Alert: Global Anti-Bribery Year-in-Review: 2018 Developments and Predictions for 2019

WilmerHale on 1/18/2019

Despite predictions of a slow-down in enforcement under the Trump administration—and indications that enforcement in some areas has decreased in the past year1—2018 was yet again an active year for FCPA enforcement. The year...more

[Webinar] 2018 Update: Anti-Corruption Compliance Enforcement and Trends - November 15th, 2:00pm ET

Jackson Lewis P.C. on 11/8/2018

The number of prosecutions under the Foreign Corrupt Practices Act (FCPA) remains steady, despite early questions about enforcement under the current administration. Additionally, the new EU General Data Protection Regulation...more

Recent Trends and Patterns in the Enforcement of the Foreign Corrupt Practices Act (FCPA) / FCPA Digest - July 2016

A&O Shearman on 7/5/2016

Shearman & Sterling’s bi-annual Trends & Patterns 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 practices in FCPA...more

Who is Responsible for Complying with the FCPA?

Thomas Fox - Compliance Evangelist on 3/9/2015

The Department of Justice (DOJ) still faces criticism over its Foreign Corrupt Practices Act (FCPA) enforcement strategy. Some decry that it is too aggressive, that the DOJ has moved into waters Congress never intended the...more

2015: The Year of FCPA Liability for Financial Institutions?

The Volkov Law Group on 2/2/2015

For years, we have all heard about the coming wave of FCPA enforcement against financial institutions, investment banks, private equity firms and others who interact with sovereign wealth funds overseas....more

Welcome to COSO and the World of Internal Controls – Part I

Thomas Fox - Compliance Evangelist on 1/29/2015

I have intentionally avoided a Top Five or Top Ten prediction list for Foreign Corrupt Practices Act (FCPA) enforcement going forward from 2014 into 2015. However there is one area of FCPA enforcement, which I think underwent...more

"United States: International Cooperation, Anti-Corruption and Tax Remain Key Issues for Enforcement Authorities"

Skadden, Arps, Slate, Meagher & Flom LLP on 1/28/2015

U.S. authorities continue to aggressively pursue cross-border investigations and to scrutinize closely the compliance programs of multinational corporations. Investigative activity by U.S. authorities in 2014 was particularly...more

2015 Trends: #7 Crime and Punishment

NAVEX on 1/21/2015

On the accountability and punishment front, three trends bear watching: 1) Deferred Prosecution Agreements (DPAs) DPAs and Non-Prosecution Agreements (NPAs) allow prosecutors to require corporate reforms and...more

FCPA Compliance and Ethics Report-Episode 121-FCPA Year in Review, Part II

Thomas Fox - Compliance Evangelist on 1/15/2015

In this episode I review the two Opinion Releases, Esquenazi court decision, DOJ communications via speeches on FCPA enforcement. I end with a look at 2015. ...more

2014 Proskauer Hedge Funds and Other Private Funds Annual Review

Proskauer Rose LLP on 12/5/2014

This year we saw a flurry of regulatory activity targeting investment advisers and hedge funds, private equity funds and other private funds (collectively, private funds). The following annual review is a summary of some of...more

DOJ and SEC Officials Focus on Enforcement, Self-Reporting and Compliance at International FCPA Conference

Akin Gump Strauss Hauer & Feld LLP on 11/25/2014

From November 18 to 19, 2014, the American Conference Institute held its annual U.S. Foreign Corrupt Practices Act (FCPA) conference outside of Washington, D.C. Keynote speakers including U.S. Department of Justice (DOJ)...more

Does Your Company’s “Inadequate Compliance Program” Violate Securities Laws?

NAVEX on 9/15/2014

In a recent matter before the SEC, settlement of an FCPA claim with Smith & Wesson has raised some worrisome new issues for compliance officers. This settlement is noteworthy for two reasons: 1. Small and mid-sized...more

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