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On October 15, the DOJ filed an indictment against a Swiss national and former executive at Maxwell Technologies—a U.S.-based energy storage and power-delivery company—for alleged violations of the FCPA. The DOJ claims that...more
On 14 August, the Serious Fraud Office (SFO) announced that four men connected to Sustainable AgroEnergy plc have been charged with offences of conspiracy to commit fraud by false representation and conspiracy to furnish...more
On May 29, the DOJ and the SEC announced that a French oil and gas company will pay nearly $400 million to resolve allegations that the company made illegal payments through third parties to an Iranian official in exchange...more
Today I finalize my review of the Total SA (Total) Foreign Corrupt Practices Act (FCPA) enforcement action....more
Yesterday I reviewed the facts surround Total SA’s (Total) lengthy bribery scheme to win contracts in Iran....more
On May 29, French oil and gas company, Total SA, agreed to pay $398 million to settle US civil and criminal allegations that it paid bribes to win oil and gas contracts in Iran in violation of the Foreign Corrupt Practices...more
On May 29, 2013, the Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) announced agreements with Total S.A. (Total) to settle alleged Foreign Corrupt Practices Act (FCPA or the Act) violations for a...more
For anyone who grew up in the 1960s, I am sure that you remember the touchstone slogan for Tareyton cigarettes, “I’d rather fight than switch”. ...more
This article examines the anti-bribery legislation of three countries, the United States, Canada, and the United Kingdom. The legislation of the three countries is compared and virtually all the criminal...more
Businesses in the oil and gas industry are cautioned to pay careful attention to evolutions in anti-corruption law in the jurisdictions where they operate. The U.S. government has successfully enforced the Foreign Corrupt...more
The art of day-to-day internal investigations has been ignored in favor of media reports on high-profile, high-stakes internal investigations.
With the increasing threat of whistleblower complaints and increasing...more
Former Italian Prime Minister Silvio Berlusconi is no stranger to scandal and controversial statements, but lately his words and actions seem to be providing cause for concern outside of the European Union....more
Several major international oil exploration companies and a logistics provider have allegedly initiated internal investigations in response to allegations of bribery involving a joint venture entity and Kazakh Customs...more
Federal prosecutors continue their aggressive enforcement of criminal laws against companies and individuals using aggressive investigative techniques, novel theories and new strategies which are testing the limits of due...more
The Justice Department and the SEC are targeting private equity companies for anti-corruption enforcement. Private equity companies are most at risk in their ownership of private equity companies....more
A key, but often overlooked, part of any anti-corruption compliance program is the need to document decisions made by the company. Documentation is critical to demonstrate the company's intent -- the absence of criminal...more
The Obama Administration is aggressively prosecuting companies for criminal violations of anti-corruption, health care, labor and environmental laws. This article examines the aruments for and against imposing criminal...more
The person of the year for 2011 -- The Chief Compliance Officer...more
This article examines the issue of materiality and FCPA disclosures...more
This article examines how to design internals to protect against bribery by foreign subsidiaries...more
A look at health care fraud enforcement and compliance program elements...more
Global retailers ahve come udner scrutiny for FCPA violations -- this article examines the risks...more
An examination of collateral litigation risks from FCPA violations...more
An examination of the Department of Justice's assertion of extra-territorial jurisdiction over foreign entities for FCPA enforcement...more
FCPA trends and predictions for 2012...more
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