Public-Private Partnerships to Stem Corruption
Episode 339: Four Sanctions Cases Everyone Should Know
Episode 338 -- Deep Dive into the Deere SEC FCPA Case
INTERPOL Red Notices - do they expire?
The Legal Tightrope: Surviving Parallel Investigations
Navigating Government Contracts: Diana Shaw on Oversight and Whistleblower Protections
The Presumption of Innocence Podcast: Episode 45 - The Grit, Grace and Gift of Second Chances
Wicked Coin: The "Fat Leonard" Scandal
Should you try to remove an INTERPOL Red Notice yourself?
Episode 335 -- The New DOJ Whistleblower Program
Navigating Civil Standing Requirements for Defense Success — RICO Report Podcast
INTERPOL Red Notices and Immigration. Can You Obtain Immigration Relief in the U.S. Even with a Red Notice?
Why Time Matters: Partners Lindsay Gerdes and Michael J. Bronson on Swift Action in Government Investigations
The Presumption of Innocence Podcast: Episode 43 - New Horizons: Impact of Recent Appellate Circuit Rulings on White-Collar Criminal Defense Law
INTERPOL and Politically Motivated Red Notices - What We Can Learn from INTERPOL’s Annual Reports.
Episode 333 -- The Boeing Proposed Plea Agreement
The Presumption of Innocence Podcast: Episode 41 - The Dynamics of Decision-Making: Psychology and the Criminal Justice System
Episode 330 – Halyna Senyk on Anti-Corruption Progress in Ukraine
What to do when finding that you are the subject of a RedNotice?
Episode 324 -- Third-Party Risks and Sanctions Compliance
For years, Department of Justice officials have stressed how important chief compliance officers are as the first line of defense in fighting corporate crimes. While that’s true, compliance programs now have a competitor in...more
The U.S. Foreign Corrupt Practices Act (FCPA) and the U.K. Bribery Act 2010, along with dozens of trade treaties and conventions, forbid consummated (and attempted) improper or unethical payments to government officials or...more
The United States District Court for the Southern District of Texas recently recognized new constitutional and extraterritorial limits on the FCPA. In an order entered November 10, 2021, the court held that it lacked...more
I have written extensively about the Novartis International AG (Novartis) Foreign Corrupt Practices Act (FCPA) settlement, which was announced in late June. However, the enforcement action paled next to the Stipulation and...more
To our bad guys, 2019 was a year flush with hope and opportunity; it ended with recidivism, more misery from Venezuela, a charlatan, an Okie who pulled a multi-million dollar fast-one on Chesapeake and, as in years past, a...more
Last Friday, the Department of Justice (DOJ) secured another trial court conviction in a Foreign Corrupt Practices Act (FCPA) prosecution involving an individual. Following on the heels of the Hoskins guilty verdict, it...more
This week I have been considering the guilty pleas of the former Unaoil Chief Executive Officer (CEO), Cyrus Ahsani, and former Chief Operations Officer (COO), Saman Ahsani, as was laid out in their Information. Most...more
This week I am mining the guilty pleas of the former Unaoil Chief Executive Officer (CEO), Cyrus Ahsani, and former Chief Operations Officer (COO), Saman Ahsani, for what they might mean for Foreign Corrupt Practices Act...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
After a sidetrack into the ethical train wreck detailed by the SEC Cease and Desist Order re: KPMG yesterday, I am returning to the blog post series I am running based upon the New York Times (NYT) reporting by Alexandra...more
In a May 17, 2019 press report that has been widely distributed in Brazil and the United States, Brazilian Federal Prosecutor Marisa Ferrari confirmed that the U.S. Federal Bureau of Investigation (FBI), the U.S. Department...more
In a three-count Indictment, another Goldman Sachs employee, Roger Ng, was charged with conspiracy to violate the FCPA and money-laundering. Ng was arrested in Singapore and will presumably be transported to the US to stand...more
The 1Malaysia Development Berhad scandal (“1MDB scandal”) has been making headlines for the past few years. The turning point for US prosecutors was the cooperation of Malaysian law enforcement and the corruption allegations...more
Well, add another pharmaceutical company to the FCPA healthcare “sweep.” Frankly, the term “sweep” makes it sound like a coordinated enforcement effort – instead, it is more accurate to think of it as multiple prosecutions...more
Yesterday Cesar David Rincon Godoy (Rincon) pled guilty to a massive money laundering scheme which took the proceeds of his corruption while he was employed at PDVSA. According to the DOJ Press Release, Rincon, a citizen of...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
You know this has been a big year in FCPA enforcement when DOJ and the SEC announce two FCPA settlements during the usually sleepy week between Christmas and New Years. And what a year it has been – more to follow in my...more
I am back from a two-week summer study program at Oxford, run by Michigan State University through its Odyssey to Oxford program. It was a great experience. My class was on The Tudors in film and print so not only did I...more
Last week, the SEC added another pharmaceutical company to its list of FCPA violators when AstraZeneca agreed to a $5.5 million settlement with the SEC. AZ is now the 25th drug or medical device company to pay an FCPA penalty...more
As the Petrobras corruption scandal seems to be going strong, we turn our attention to what may be the most corrupt of all the national energy companies, the Venezuelan state oil company Petroleos de Venezuela SA (PDVSA)....more
Eye on the Supreme Court—Corruption and Fraud Edition - Why it matters: This session, the Supreme Court has undertaken the review of numerous cases that raise thorny issues arising in the white collar context. In our...more
First it was Petrobras but it certainly did not take long for the second shoe to drop for the other corrupt national energy company in Latin America, the Venezuelan national oil company Petróleos de Venezuela, also known as...more
In the wreckage of a corporate FCPA enforcement action, a company has to answer two important questions. First, how did the conduct occur without senior executives and the Board learning or suspecting that such conduct...more
On this date in 2008 George Carlin died. If you grew up in the late 1960s or early 1970s and you had anti-parental or anti-establishment inklings, which of course all teenagers do, you knew about George Carlin. In the early...more
Today, I continue my four-part series on the above question posed to me recently by a colleague. In Part I, I wrote that only the US government had the wherewithal, tools and will to do so. Yesterday, I focused on corruption...more