Key Takeaways-
•On March 1, 2023, the Assistant Attorney General (“AAG”) for the Criminal Division of the U.S. Department of Justice (“DOJ”), Kenneth A. Polite, Jr., issued a revised memorandum on the imposition and...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 case developments from the past month,...more
12/22/2021
/ Anti-Bribery ,
Anti-Corruption ,
Anti-Money Laundering ,
Bribery ,
Corporate Counsel ,
Corruption ,
Department of Justice (DOJ) ,
FINMA ,
Foreign Corrupt Practices Act (FCPA) ,
OECD ,
Popular ,
Securities and Exchange Commission (SEC) ,
Whistleblowers
In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international anti-corruption developments from the past month, with links to primary...more
7/17/2020
/ Anti-Corruption ,
Bribery ,
Corporate Counsel ,
Department of Justice (DOJ) ,
Foreign Corrupt Practices Act (FCPA) ,
Freelance Isn't Free Act (FIFA) ,
International Foreign Bribery Taskforce (IFBT) ,
Money Laundering ,
NCAs ,
Novartis ,
Pharmaceutical Industry ,
Popular ,
SCOTUS ,
Securities and Exchange Commission (SEC) ,
SFO ,
UK ,
Whistleblowers
On June 1, 2020, the U.S. Department of Justice (“DOJ”) published a revised version of its guidance on the “Evaluation of Corporate Compliance Programs” (the “June 2020 Guidance”). Like its predecessors in February 2017 and...more
On April 30, 2019, the Assistant Attorney General (AAG) for the U.S. Department of Justice’s Criminal Division, Brian Benczkowski, announced the release of an updated version of the “Evaluation of Corporate Compliance...more
In early March 2019, the Department of Justice (DOJ) revised its Foreign Corrupt Practices Act (FCPA) Corporate Enforcement Policy (the Policy). First announced in November 2017, the Policy is designed to encourage companies...more
In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international anti-corruption developments in the past month, with links to primary...more
3/20/2019
/ Anti-Corruption ,
Brazil ,
Bribery ,
Corporate Counsel ,
Department of Justice (DOJ) ,
Foreign Corrupt Practices Act (FCPA) ,
Fraud ,
Popular ,
Securities and Exchange Commission (SEC) ,
Sweden ,
UK ,
Venezuela ,
Whistleblowers
On March 8, 2019, DOJ announced that it had made revisions to its November 2017 FCPA Corporate Enforcement Policy (“the Policy”). The revised Policy includes a number of changes, but most notably softens DOJ’s prohibition on...more
In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international anti-corruption developments from the past month, with links to primary...more
10/9/2018
/ Anti-Corruption ,
Argentina ,
Brazil ,
Bribery ,
Canada ,
Corporate Counsel ,
Department of Justice (DOJ) ,
Financial Services Industry ,
Foreign Corrupt Practices Act (FCPA) ,
Guilty Pleas ,
Popular ,
Securities and Exchange Commission (SEC) ,
Switzerland ,
UK ,
Uzbekistan
In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international anti-corruption developments from the past month, with links to primary...more
12/23/2017
/ Anti-Bribery ,
Anti-Corruption ,
Argentina ,
Bribery ,
Corporate Counsel ,
Corruption ,
Department of Justice (DOJ) ,
DPA ,
Fédération Internationale de Football Association (FIFA) ,
Foreign Corrupt Practices Act (FCPA) ,
France ,
Securities and Exchange Commission (SEC) ,
UK
In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international anti-corruption developments from the past month, with links to primary...more
6/1/2017
/ Anti-Corruption ,
Australia ,
Brazil ,
Bribery ,
Compliance ,
Construction Industry ,
Corporate Counsel ,
Corruption ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Foreign Corrupt Practices Act (FCPA) ,
Securities and Exchange Commission (SEC) ,
Serious Fraud Office (SFO) ,
South Korea
In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international anti-corruption developments from the past month, with links to primary...more
2/1/2017
/ Anti-Corruption ,
Bribery ,
Corruption ,
Department of Justice (DOJ) ,
DPA ,
Evidence ,
Foreign Corrupt Practices Act (FCPA) ,
Manufacturers ,
Money Laundering ,
Pharmaceutical Industry ,
Securities and Exchange Commission (SEC) ,
UK ,
United Airlines
On April 5, 2016, Assistant Attorney General Leslie Caldwell, who heads the Criminal Division of the U.S. Department of Justice, announced a new “FCPA pilot program” designed to motivate companies to voluntarily self-disclose...more
On April 4, 2016, the U.S. Department of Justice filed a civil antitrust lawsuit against activist investor ValueAct Capital. The DOJ asserts that ValueAct improperly relied on the “investment only” exemption to the...more
On April 5, 2016, Assistant Attorney General Leslie Caldwell, who heads the Criminal Division of the Department of Justice (DOJ), announced a new “FCPA pilot program” designed to motivate companies to voluntarily selfdisclose...more
On April 4, 2016, the U.S. Department of Justice (DOJ) filed a civil antitrust lawsuit against activist investor ValueAct Capital (“ValueAct”). DOJ asserts that ValueAct improperly relied on the “investment only” exemption to...more
In 2015, the Department of Justice (DOJ) made more news for the corporate Foreign Corrupt Practices Act (FCPA) cases that it did not bring than for the two that it did bring: Nine times last year, DOJ declined to join...more
On August 24, 2015, the Federal Trade Commission (“FTC” or the “Commission”) filed a proposed settlement in federal court regarding alleged violations by Third Point LLC (“Third Point”) of the premerger reporting laws related...more
9/1/2015
/ Board of Directors ,
Competition ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Federal Trade Commission (FTC) ,
Hart-Scott-Rodino Act ,
Investment-Only Exemption ,
Reporting Requirements ,
Third Point ,
Voting Securities ,
Yahoo!
On June 1, 2015, Canada’s Extractive Sector Transparency Measures Act (“ESTMA” or “the Act”) came into force. Approved in December 2014, but not in force until this month, the Act requires companies in the extractive sector...more
7/27/2015
/ Anti-Bribery ,
Anti-Corruption ,
Bribery ,
Canada ,
Compliance ,
Enforcement ,
Extractive Industry Transparency Rule ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Official ,
Internal Controls ,
Mineral Extraction ,
Multinationals ,
New Legislation ,
Oil & Gas ,
Penalties ,
Reporting Requirements ,
Resource Extraction ,
State-Owned Enterprises
On June 1, 2015, Canada’s Extractive Sector Transparency Measures Act (“ESTMA”) came into force. Approved in December 2014, but not in force until this month, the act requires companies in the extractive sector to report...more
In recent years, the Securities and Exchange Commission (SEC) and Financial Industry Regulatory Authority (FINRA) have heightened their expectations of what constitutes a “comprehensive” branch self-inspection program. Firms...more
On November 6, 2014, FINRA released results from a survey of U.S. investors measuring the demand for additional regulatory protections. The survey polled 1,000 adults and revealed that an overwhelming majority felt that it...more
THE FTC ISSUES AMENDED FRED MEYER GUIDES -
On September 24, 2014, the Federal Trade Commission (FTC) approved final amendments to the Fred Meyer Guides (“Guides”). The Guides are intended to help businesses comply with...more
Financial Industry Regulatory Authority (FINRA) rules require member firms to establish and maintain a system of written procedures to supervise the activities of its members. On December 23, 2013, the SEC approved new FINRA...more