International Trade Criminal Law Administrative Agency

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OECD Slams France for Lacklustre Bribery & Corruption Enforcement

International pressure is mounting for France to boost their anti-bribery and corruption efforts, but French organisations face the most serious risks—and have the greatest need for strong compliance programmes—today....more

UK Home Affairs Committee – Evaluating the National Crime Agency

On 17 February, the House of Commons Home Affairs Committee published its report on the architecture of policing in the United Kingdom. This report follows a period of five years of restructuring and reshaping policing at the...more

This Week In Securities Litigation

The Commission resolved its actions against the PRC based affiliates of five major accounting firms for failure to produce audit work papers. The settlement contains a series of procedures designed to facilitate production in...more

INTERPOL’s CCF increases its sessions for 2015- an encouraging sign

It appears that one of the first orders of business upon Nina Vajic‘s assuming her post as Chair of the Commission for the Control of INTERPOL’s Files (CCF) was to increase the number of scheduled sessions for the year....more

DOJ Announces First FCPA Enforcement Action of 2015

Last week, the Department of Justice announced the first Foreign Corrupt Practices Act enforcement action of 2015, against Dmitrij Harder, the former owner and president of the Chestnut Consulting Group. The allegations are...more

This Week In Securities Litigation

FCPA enforcement was the focus this first week of the new year. The DOJ brought FCPA and Travel Act charges against an individual alleged to have repeatedly bribed an official of the European Bank of Reconstruction and...more

Alstom Joins Santa’s Naughty List – In a Very Big Way

The North Pole for Foreign Corrupt Practices Act (FCPA) enforcement action announcements seems to have temporarily moved south for the month of December. Last week there was the final announcement of the long-standing Avon...more

A new leader for the Commission for the Control of INTERPOL’s Files

INTERPOL has a new Chairperson for the Commission for the Control of INTERPOL’s Files, which is the quasi-appellate arm of the organization. Nina Vajic assumed her new post as Chairperson in September....more

This Week In Securities Litigation

The Commission brought a series of administrative proceedings this week and one civil injunctive action. The civil injunctive action was an insider trading case. The administrative proceedings centered on FCPA violations, the...more

Stacking the Deck: SEC’s Use of Administrative Proceedings

The SEC has a real perception problem. They cannot win in court. Whether this is fair or not, the SEC needs to move beyond this fear of losing since it only undermines the integrity of its enforcement program....more

Administrative and criminal violations involving the same fact: the recent positions of the European Court of Human Rights and of...

The European Court of Human Rights takes a stand on the ne bis in idem principle intervening on the relationship between administrative and criminal violations involving identical facts. Two recent decisions give interesting...more

"SEC Judge Issues Initial Decision Regarding Chinese Affiliates of the Big Four Accounting Firms"

On January 22, 2014, U.S. Securities and Exchange Commission Administrative Law Judge Cameron Elliot (the ALJ) issued an initial decision censuring the Chinese accounting firms affiliated with Ernst & Young LLP, KPMG LLP...more

Corporate Compliance Policies – Interview with Bridget Rohde, Member, Mintz Levin [Video]

Attorney Bridget Rohde, Member of Mintz Levin's Litigation Practice, discusses the importance of comprehensive corporate compliance policies....more

United States of America v. Ross William Ulbricht

Federal indictment against Silk Road founder Ross Ulbricht for narcotics trafficking, computer hacking, and money laundering

Full text copy of the federal indictment filed September 27, 2013 against Silk Road founder Ross Ulbricht – aka Dread Pirate Roberts, DPR, and Silk Road – for narcotics trafficking, computer hacking, and money laundering (the...more

"Ranbaxy Resolves Criminal and Civil Charges Through Record Settlement"

Executive Summary - On May 13, 2013, generic drug manufacturer Ranbaxy USA Inc. (Ranbaxy), a subsidiary of Indian generic drug manufacturer Ranbaxy Laboratories Limited, pled guilty to seven felony charges as part of a...more

Commerce Takes A More Aggressive Stance On Fraud by Jef Denning

In the March 2011 edition edition of the Trade and Manufacturing Alert, we reported on the decision by the United States Court of Appeals for the Federal Circuit in Home Products Int’l v. United States, 633 F.3d 1369 (2011),...more

Justice Department and SEC Issue Guidance on Anti-Bribery Law

Originally published in Swampfox - January 22, 2013. In November 2012 the Department of Justice and the Securities and Exchange Commission issued a 120-page “resource guide” to the U.S. Foreign Corrupt Practices Act. ...more

The Financial Services Act 2012 – Misleading Statements, Impressions and Financial Promotions

Background - In our previous DechertOnPoints, The Draft Financial Services Bill in the Contextof the Proposed New UK Financial Regulatory Structure and Draft UK Financial Services Bill and the New UK Financial...more

Rolls-Royce Brings in Lord Gold – Is it Thinking Big Enough?

In December 2012 the BBC online service reported that Rolls-Royce Motor Cars Limited (Rolls-Royce) was in talks with the UK Serious Fraud Office (SFO) regarding potential allegations of bribery and corruption in Indonesia and...more

Fu Manchu and the Wal-Mart FCPA Investigation Water Torture

Today we celebrate Fu Manchu. No not the facial accouterments but the fictional character who was introduced to the world in a series of novels by British author Sax Rohmer during the first half of the 20th century. He has...more

Internal Audit Review of Charitable Donations Under the FCPA

When is a rose not a rose? When it is a charitable donation not made for philanthropic purposes and it violates the Foreign Corrupt Practices Act (FCPA). I thought about that concept when reviewing the Eli Lilly and Company...more

Top Ten Enforcement Actions for 2012

As we welcome in 2013, it is appropriate to reflect back on some of the things which have occurred over 2012 and in the Foreign Corrupt Practices Act (FCPA) enforcement world, it was quite a significant year. The Department...more

INTERPOL Denies Any Withdrawal from Relationship with Iraq

Yesterday, numerous media outlets reported that INTERPOL had suspended its involvement with member country Iraq. Those reports were made (see article below for links). The purported basis for the suspension was a lack of...more

Five Biggest FCPA Stories Of 2012

One of my favorite “Seinfeld” episodes is when Jerry and George go to NBC to pitch their new television show which is about “nothing.” There are some parallels to this posting. FCPA settlements have dwindled during 2012....more

China’s Antitrust Authority Imposes Fines on Foreign Corporations for the First Time

Recently China’s National Development and Reform Commission (NDRC) imposed an RMB 353 million (USD 56.7 million) penalty against an international price-fixing cartel of LCD manufacturers, the largest the NDRC has ever imposed...more

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