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Acquisitions Corruption

A&O Shearman

What the U.S. Department of Justice’s new M&A safe harbor policy means for PE firms

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On October 5, 2023, Deputy Attorney General, Lisa Monaco, announced a new safe harbor policy for voluntary self-disclosures made in the mergers and acquisitions context. The safe harbor policy will apply Department-wide and...more

McDermott Will & Emery

International Legal Highlights | Winter 2023

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THE EUROPEAN COMMISSION PUBLISHES FINAL IMPLEMENTING REGULATION ON PROCEEDINGS PURSUANT TO THE FOREIGN SUBSIDIES REGULATION - On July 10, 2023, the European Commission (the “Commission”) published its final regulation for...more

Sheppard Mullin Richter & Hampton LLP

Voluntary Self-Disclosure of FCPA Violations Following Acquisition Avoids Corruption Charges

Last week, the Department of Justice (“DOJ”) announced it declined to prosecute Lifecore, a U.S. biomedical company, after Lifecore voluntarily disclosed that a company it acquired paid bribes to Mexican officials and...more

Torres Trade Law, PLLC

OFAC Sends Clear Message to Parties Conducting Business with Entities on OFAC’s Sectoral Sanctions Identification List

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As the U.S. and the European Union continue to impose new sanctions on Russia in response to the invasion of Ukraine, regulatory authorities continue their pursuit of companies and individuals who violate those sanctions. The...more

Thomas Fox - Compliance Evangelist

WPP Enforcement Action: Part 2 – Structural Compliance Deficiencies

This week we are exploring the recent Securities and Exchange Commission (SEC) Cease and Desist Order (Order) entered into last week with WPP plc, the world’s largest advertising group, for paying bribes to Indian government...more

White & Case LLP

Examining the ABC risks as the mining & metals sector gains critical momentum

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Key considerations around bribery and corruption risks, as the mining & metals sector is gaining critical momentum in the world's energy transition toward a low-carbon future. Mining & metals in a low-carbon world - The...more

Thomas Fox - Compliance Evangelist

Foster Wheeler Settles Corruption Allegations – Bada Bing, Bada Bang and Lessons Learned

I conclude my review of the Amec Foster Wheeler (Foster Wheeler) Foreign Corrupt Practices Act (FCPA) enforcement action. Today, I want to close with the result and some key lessons for the 2021 compliance professional. These...more

Thomas Fox - Compliance Evangelist

Cardinal Health FCPA Enforcement Action: High Risk Business Relationships

Cardinal Health Inc. (Cardinal) settled its Foreign Corrupt Practices Act (FCPA) matter with the Securities and Exchange Commission (SEC) last week. According to the SEC Press Release, Anita B. Bandy, Associate Director in...more

Butler Snow LLP

2019 Developments and Trends in the Foreign Corrupt Practices Act (FCPA) & Global Anti-Corruption Efforts, Part 3 of 3

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Previously we introduced you to the FCPA and provided updates about the positive international trends in anti-corruption legislation; efforts to punish and deter bribery; the Organization for Economic Cooperation and...more

Robins Kaplan LLP

Financial Daily Dose 10.3.2019 | Top Story: After WTO ruling, US Hits EU with $7.5B in Tariffs Over Airbus Subsidies

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We now have a price tag on the WTO-authorized sanctions that the U.S. can impose on European goods as a result of the EU’s illegal subsidies of planemaker Airbus: $7.5 billion—the “largest authorized retaliation in the WTO’s...more

Thomas Fox - Compliance Evangelist

Gary P. Nunn, Redneck Rock and Opinion Release 04-02

One of the complaints still made about the Department of Justice (DOJ) is that companies are not made aware of the requirements of a best practices compliance program. ...more

Hogan Lovells

Successor liability: Stamping out corruption is good for business

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The responsibility to "clean up" corrupt business practices in the developing world has more often than not fallen to foreign-based investors as opposed to the authorities in those countries....more

Alston & Bird

DOJ Extends FCPA Corporate Enforcement Policy to Mergers and Acquisitions

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Our Government & Internal Investigations Team discusses the implications of the Justice Department’s decision to extend its FCPA Corporate Enforcement Policy to M&A transactions and how acquiring and successor corporations...more

Thomas Fox - Compliance Evangelist

Evolution of Best Practices – Part IV

In addition to enforcement actions, the Department of Justice’s (DOJs) 2016 FCPA Pilot Program, coupled with 2017’s Evaluation of Corporate Compliance Programs (Evaluation) and the FCPA Corporate Enforcement Policy, all...more

BCLP

Anti-Corruption Enforcement: Analyzing the Enforcement Approaches of the US, the UK and France

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Anti-Corruption enforcement is a top priority in France, the UK, and the US. Each of these countries has armed its enforcers with the enforcement tools necessary to investigate and prosecute corporations and individuals. Join...more

Thomas Fox - Compliance Evangelist

Embraer FCPA Enforcement Action – Part III

Today I continue my exploration of the recently announced Department of Justice (DOJ) and Securities and Exchange Commission (SEC) Foreign Corrupt Practices Act (FCPA) enforcement action with the announcement of the...more

FordHarrison

[Event] "Americas Labor & Employment Law Conference: Managing a workforce across the Americas and beyond" - Dec. 8th-9th, Miami,...

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Attorneys from FordHarrison and Ius Laboris, the global Alliance of leading labor and employment law firms, will join in-house counsel to discuss the many challenges faced by multinational companies. The conference is aimed...more

Thomas Fox - Compliance Evangelist

The Ping FCPA Enforcement Action: Lessons for the Compliance Practitioner

The Securities and Exchange Commission (SEC) settled a Foreign Corrupt Practices Act (FCPA) enforcement action against an individual earlier this month when it announced the resolution of a matter involving Jun Ping Zhang,...more

The Volkov Law Group

For An Effective Ethics and Compliance Program — First, Train Your Board and Senior Executives

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Compliance professionals are familiar with the phrase “tone at the top,” but what exactly does it mean? Unlike other compliance program components, it cannot be easily formalized and implemented in a policy or procedure....more

Thomas Fox - Compliance Evangelist

Hallmark 10 – Mergers and Acquisitions: Pre-Acquisition Due Diligence and Post-Acquisition Integration

The FCPA Guidance notes that one of the ten hallmarks of an effective compliance program is around mergers and acquisitions (M&A), in both the pre and post-acquisition context. A company that does not perform adequate FCPA...more

Thomas Fox - Compliance Evangelist

Lunch with the FCPA Compliance and Ethics Blog – Donald Anderson of TDI

I recently had the chance to sit down for a lovely lunch at the Federal Grille with Donald Anderson, the Partner in Charge for TD International’s (TDI) Houston Office. Donald is a Louisiana native who attended LSU, receiving...more

Dorsey & Whitney LLP

Goodyear Settles SEC FCPA Charges

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Goodyear Tire and Rubber Company settled FCPA books and records and internal control charges with the SEC. The settlement reflects the extensive cooperation and remedial efforts of the company. In the Matter of Goodyear Tire...more

Bennett Jones LLP

Look(s) Bad for Former Directors

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In its decision in Cytrynbaum v. Look Communications Inc. released July 4, 2013, the Ontario Court of Appeal affirmed a lower court ruling that "advancement" by the corporation to Look's former directors, for advance funding...more

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