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Thomas Fox - Compliance Evangelist

10 Compliance Lessons Learned from the Telefónica Venezolana FCPA Enforcement Action

Last week, the Department of Justice (DOJ) announced a resolution of a Foreign Corrupt Practices Act (FCPA) enforcement action involving Telefónica Venezolana, the Venezuelan subsidiary of Telefónica S.A. (Telefónica)...more

A&O Shearman

Looking Back And Moving Forward – 2023 FCPA Enforcement Trends And Patterns

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While 2023 saw a slight increase in the number of FCPA enforcement actions from 2022, there was a marked decline in total penalties from the prior year. Last year, the DOJ and the SEC resolved a total of 14 corporate...more

The Volkov Law Group

John Deere Reaches $9.9 Million Settlement with SEC over FCPA Violations

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The U.S. Securities and Exchange Commission (“SEC”) recently instituted proceedings against Deere & Company (“John Deere”), a leading global manufacturer of agricultural and heavy machinery, for multiple violations of the...more

The Volkov Law Group

RTX Corporation Reaches Record $200 Million Settlement with DDTC for Serial Violations of the AECA and ITAR

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On August 30, 2024, the U.S. Department of State’s Directorate of Defense Trade Controls (“DDTC”) announced the settlement of a record $200 million administrative enforcement action with RTX Corporation—a multinational...more

Skadden, Arps, Slate, Meagher & Flom LLP

EU Court Upholds Commission’s Power To Demand Data Held by Foreign Companies

In Nuctech Warsaw (T-284/24), the EU Court of Justice held that EU subsidiaries can lawfully be required to provide access to email accounts and data held by their overseas parent company. The ruling involved the following...more

McDermott Will & Emery

DOJ Unveils Details of Corporate Whistleblower Awards Pilot Program

On August 1, 2024, the US Department of Justice’s (DOJ’s) Principal Deputy Assistant Attorney General of the Criminal Division, Nicole Argentieri, unveiled the highly anticipated details of DOJ’s Corporate Whistleblower...more

Fox Rothschild LLP

The Presumption of Innocence Podcast: Episode 41 - The Dynamics of Decision-Making: Psychology and the Criminal Justice System

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Human errors can irrevocably alter the course of someone’s life in the criminal justice system. In a fascinating follow-up to Episode 40 on the role of pseudoscience in the courtroom, Dan Simon joins host Matt Adams to...more

Jones Day

Raids by Asia-Pacific Enforcers Are on the Rise: A Guide to Being Prepared for When the Enforcer Comes Knocking

Jones Day on

The Development: After an interruption during the COVID-19 pandemic, authorities across the Asia-Pacific region have fully revived dawn raids....more

The Volkov Law Group

Trafigura Joins the FCPA Enforcement Club: Pleads Guilty and Pays Over $126 Million for Bribery Violations in Brazil (Part I of...

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On the heels of the Gunvor FCPA settlement for $661 million, DOJ announced its settlement with Trafigura, the latest commodities trading company to fall under DOJ’s FCPA Sweep against the industry.  Trafigura joined the list...more

Foley Hoag LLP - White Collar Law &...

SEC to Continue Aggressive Enforcement Efforts in 2024 After Record-Setting 2023

This is the fourth in our 2024 Year in Preview series examining important trends in white collar law and investigations in the coming year. We will be posting further installments in the series throughout the next several...more

A&O Shearman

Regulators and reforms: how Australia tackled white collar crime in 2023 and what to expect in 2024

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Regulators and enforcement authorities in Australia intensified their efforts to curb white-collar crime in 2023. They targeted fraud, money laundering, tax evasion, cybercrime, and corruption across multiple industries,...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for November 2023

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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

The Volkov Law Group

Clear Channel Settles SEC FCPA Case Against Former Chinese Subsidiary for $26.1 Million

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The Securities and Exchange Commission continues to rack up FCPA enforcement actions.  In its latest settlement, Clear Channel Outdoor Holdings agreed to pay $26.1 million for bribery violations committed by its former...more

Akin Gump Strauss Hauer & Feld LLP

New DOJ Focus on Executive Compensation in Resolving Criminal Investigations

Key Points - The DOJ recently announced several policy updates tethering resolution of criminal investigations to a company’s compensation and bonus programs. These updates include executive compensation focused...more

Orrick, Herrington & Sutcliffe LLP

In Like a Lion: DOJ Marks March with a Series of New Compliance Policies

DOJ is roaring into March with updates to its guidance on the evaluation of corporate compliance programs, a new pilot program on compensation incentives and clawbacks, and a revised policy on monitor selection, all released...more

Orrick, Herrington & Sutcliffe LLP

U.S. Department of Justice Rolls Out New Policy to Incentivize Companies to Implement Executive Compensation Systems that...

During a March 2, 2023, speech in Miami at the annual American Bar Association National Institute on White Collar Crime, Deputy Attorney General Lisa Monaco announced a new policy designed to incentivize companies to factor...more

Morgan Lewis

DOJ Announces Compensation Clawback Pilot Program, Changes to Corporate Compliance Program Evaluation Criteria

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The US Department of Justice recently announced a compensation clawback pilot program as well as changes to the corporate compliance program evaluation criteria in the latest of a flurry of policy updates....more

Sheppard Mullin Richter & Hampton LLP

Corporate Voluntary Self-Disclosure (VSD) of Criminal Activity: More of the Same or a Real Sea Change?

On February 22, 2023, the U.S. Department of Justice (DOJ) announced a new nation-wide policy to incentivize companies to self-report criminal activity. Among the cited benefits of self-reporting are discounts on fines and...more

A&O Shearman

DOJ Announces Revisions To The Criminal Division’s Corporate Enforcement Policy

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On January 17, 2023, Assistant Attorney General Kenneth A. Polite delivered remarks announcing revisions to the Department of Justice (“DOJ”) Criminal Division’s Corporate Enforcement Policy (“CEP”) at Georgetown Law Center. ...more

NAVEX

The Justice Department Steps Up Its Compliance Message

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The U.S. Justice Department unveiled new policies about how it will prosecute cases of corporate misconduct, offering new incentives for companies whose misconduct includes “aggravating circumstances” to step forward and...more

The Volkov Law Group

2022: The FCPA Year in Review

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The Justice Department and the Securities and Exchange Commission bounced back in 2022 to restore their records for aggressive FCPA enforcement.  At the same time, DOJ announced significant new compliance program...more

Foley Hoag LLP - White Collar Law &...

The DOJ Gets the Green Light in its Latest No-Poach Criminal Prosecution

It has been a tumultuous year for the Department of Justice (“DOJ”) and its recent no-poach criminal prosecution strategy. No-poach agreements, which are arrangements between companies that place restrictions on the hiring...more

Orrick, Herrington & Sutcliffe LLP

Enforcement Uptick & Individual Accountability: Here’s What to Know from DOJ’s Updates to Enforcement Policies

The Department of Justice (“DOJ” or the “Department”)’s signals that it is doubling down on corporate criminal enforcement, including focusing on individual accountability, deserve close attention. The updates, announced by...more

The Volkov Law Group

VMware pays SEC $8 Million for Misleading Financial Reporting

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The Securities and Exchange Commission’s bread-and-butter enforcement actions focus on accounting fraud.  The SEC has a long history in uncovering fraudulent financial reporting schemes.  In the early 2000s, Wall Street was...more

White & Case LLP

DOJ Announces New Changes to Corporate Criminal Enforcement Policies

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On September 15, 2022, Deputy Attorney General Lisa Monaco announced new changes to the United States Department of Justice's (the "DOJ") corporate criminal enforcement policies, through the publication of a new memo titled...more

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