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No Safe Haven: DOJ Can and Will Seize Proceeds of Wholly Foreign Corruption

Nine pieces of real property in the New Orleans area purchased and owned by Honduran government official Mario Roberto Zelaya Rojas (“Zelaya”) are proceeds of criminal activity and subject to seizure, according to a civil...more

2015 Trends: #7 Crime and Punishment

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

China Regulatory Enforcement Quarterly - Noteworthy developments and insights from the fourth quarter of 2014

In This Issue: - Executive Summary - PRC Legal and Regulatory Updates - Major Enforcement News - The Pharmaceutical Blacklist: A Look Back - After One Year - PRC Anti-Corruption 101 - Frequently Asked...more

Alstom Guilty Plea Sends Strong Message that DOJ Has Harsh View of Inadequate Internal Controls and Failure to Fully Cooperate

On December 22, 2014, French power and transportation company Alstom S.A. (“Alstom”) pleaded guilty to violating the Foreign Corrupt Practices Act (“FCPA”) and agreed to pay $772.29 million, the largest criminal fine ever...more

Financial Services Regulatory Update: FX Investigations: Lessons Learnt From International Investigations

As the Australian Securities and Investments Commission (ASIC) and the Australian Competition and Consumer Commission (ACCC) continue their respective investigations of the conduct of financial institutions in relation to...more

Canada Counters Counterfeiting: Border Enforcement Provisions of CCPA Come into Force

After years of calls for reform from intellectual property rights owners, the Canadian government has enacted new legislation in an effort to fight counterfeiters acting on a commercial scale. Bill C-8, the Combating...more

Cosmetics Giant Puts Up $135 Million for FCPA Violations

The Chinese subsidiary of a major U.S. cosmetics company recently pleaded guilty to violations of the Foreign Corrupt Practices Act (FCPA) and agreed to pay $67.7 million to settle criminal charges with the Department of...more

DOJ Kicks Off 2015 with an FCPA Enforcement Action Against a Former President of a Philadelphia Consulting Company

The U.S. Department of Justice (“DOJ”) wasted no time announcing its first Foreign Corrupt Practices Act (“FCPA”) case of 2015. On January 6, 2015, just two days into the first full week of the new year, Dmitrij Harder, the...more

A “Pivotal Time” for the UK Serious Fraud Office: SFO Secures First Convictions Against Individuals and a Corporation for Bribery...

In December 2014, the U.K. Serious Fraud Office (“SFO”) secured its first criminal convictions against a number of individuals for offenses under the Bribery Act 2010 (the “Act”) and, in a separate case, a corporation for...more

Justice Department Files First FCPA Case of 2015, Reminds Lawyers to Watch Out

Last week, the Justice Department filed the first FCPA case of 2015 when it indicted Dmitrij Harder, the former owner and president the Chestnut Consulting Group in Huntingdon Valley, Pa. ...more

2015 Trends: #4 Maybe One Size Does Fit All: Moving Toward a Uniform, Global Model for Compliance

We asked industry experts, colleagues and compliance officers what they believe will be the top issues impacting workplace ethics and corporate compliance programs in 2015. We gathered their best thinking and prepared our...more

Reconciling Sales Strategy With FCPA Compliance

When Ethical Boardroom asked me to contribute an article on the Foreign Corrupt Practices Act (FCPA) and international sales strategies, I thought it might be interesting to include an organisational change dimension in...more

Former Toyoda Gosei Executive Pleads Guilty to Price-Fixing, Bid-Rigging

On January 6, 2015, Makoto Horie of Toyoda Gosei North America pled guilty to the United States Department of Justice (DOJ) for conspiring to fix the prices of automotive hoses sold to U.S. companies. Mr. Horie was sales...more

[eBook] The Revolution in Ethics and Compliance

In this collection of recent essays and blog posts, attorney, leading compliance expert, and former federal prosecutor Michael Volkov helps corporate leaders understand how a culture of ethics and compliance is not only the...more

Recent Trends and Patterns in Foreign Corrupt Practices Act (FCPA) Enforcement

In this memo: - Enforcement Actions and Strategies - Perennial Statutory Issues - Compliance Guidance - Unusual Developments - Private Litigation - Enforcement in the United...more

Top Ten International Anti-Corruption Developments for December 2014

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

The DOJ Charges Another Individual With FCPA Violations

FCPA enforcement officials have repeatedly emphasized that a key focus is individuals who violate the Act. This week the Department of Justice announced the filing of a multi-count indictment against the owner of a privately...more

Global Cartel Enforcement - 2014 Year In Review

To name only a few, the U.S. faced challenges over the extent of its jurisdictional reach; China was criticised for questionable investigative practices and allegedly protectionist use of its antitrust powers; and Japan faced...more

DIFC Market Abuse Regime - DFSA publishes Code of Market Conduct

On 16 December the Dubai Financial Services Authority (‘DFSA’) published its Code of Market Conduct (the ‘Code’) which will apply from 1 January 2015. The Code is intended to provide guidance and clarity to the market abuse...more

Avon Settles FCPA Charges

On December 17, 2014, Avon Products, Inc. (“Avon”) resolved Foreign Corrupt Practices Act (FCPA) investigations being conducted by the Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) with a...more

December FCPA Enforcement Digest – Let’s Celebrate the New Year with Anti-Bribery Training!

Happy New Year! I hope everyone had a wonderful holiday and a great start to the New Year. With that said, I hope you’re not suffering from the holiday hangover (and I don’t mean the alcohol-induced kind.) After taking...more

The Alstom FCPA Enforcement Action – Part I

As the first blog post of 2015, I thought it appropriate to highlight two outstanding confluences. The first is that this year is the centenary of the birth of Orson Welles. While not occurring in 2015, near the end of 2014...more

Red Notice Newsletter - December 2014

Welcome to the December 2014 edition of Red Notice, a publication of Akin Gump Strauss Hauer & Feld LLP. This month on the anticorruption front, a major cosmetics retailer as well as its subsidiary pleads guilty to...more

Alstom’s FCPA Guilty Plea and Fine of $772 Million Offer Compelling Lessons

The December 23, 2014, announcement by the U.S. Department of Justice (DOJ) that Alstom, S.A., a French power and transportation company, pled guilty to two Foreign Corrupt Practices Act (FCPA) charges and agreed to pay $772...more

Alstom to Pay Largest FCPA Criminal Penalty in History

Earlier this week, Alstom S.A., a French multinational power and transportation company, pleaded guilty in the District of Connecticut to a two-count information charging it with violating the accounting provisions of the...more

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