FCPA Compliance and Ethics Report-Episode 131, The FCPA Professor Takes a Look Back at 2014
FCPA Compliance and Ethics Report-Episode 122-with Matt Kelly on Alstom, Avon and Petrobras
FCPA Compliance and Ethics Report-Episode 119-FCPA Year in Review, Part I
FCPA Compliance and Ethics Report-Episode 118-the Alstom FCPA Enforcement Action
FCPA Compliance and Ethics Report-Episode 115-Tom Fox and Matt Kelly on COSO, Bruker Corp, Dallas Airmotive and Alstom
A recent US District Court for the District of Connecticut decision reveals the practical limits of the Foreign Corrupt Practices Act (FCPA) in cases involving foreign nationals, foreign conduct and complex multinational...more
In its continuing aggressive FCPA criminal enforcement program, DOJ announced the indictment of two former Alstom executives and a former Marubeni executive with FCPA violations arising from a bribery scheme in Indonesia....more
The year 2019 has been something of a mixed bag for the UK’s criminal and regulatory authorities. While the Serious Fraud Office (“SFO”) and Financial Conduct Authority (“FCA”) appear to have taken involuntary sabbaticals...more
Compound Ingredient Supplier to Pay Over $22 Million to Resolve Allegations Brought Under Qui Tam Provisions of FCA - On November 7, 2019, the Department of Justice (DOJ) announced that Fagron Holding USA LLC (Fagron) had...more
Lawrence Hoskins, a UK citizen and former Alstom executive, was convicted last Friday on 11 of 12 counts for his role in a bribery scheme involving Indonesian officials....more
Anti-Corruption enforcement remained a top priority in France, the UK, and the US in 2018. Join our firm's Global Anti-Corruption Team as they explain and analyze these three countries' anti-corruption enforcement efforts and...more
Conspiracy and Aiding-and-Abetting Charges Cannot Expand Territorial Reach of the FCPA to a Non-US Defendant Who Otherwise Would Not Be Liable for His Ex-US Conduct - United States v. Hoskins, US Court of Appeals for the...more
On August 24, the U.S. Court of Appeals for the Second Circuit issued a decision that announced a new and important limitation on the application of the Foreign Corrupt Practices Act (FCPA)....more
Ruling holds that the government cannot use conspiracy and accomplice liability theories to reach foreign nationals that lack US ties. Key Points: ..Non-resident foreign nationals who are not otherwise subject to direct...more
On August 24, 2018, the US Court of Appeals for the Second Circuit in United States v. Hoskins rejected the government’s broad reading of the Foreign Corrupt Practices Act (FCPA) and ruled that a foreign national without ties...more
Enforcement of the Foreign Corrupt Practices Act was a high priority for the Department of Justice and the Securities and Exchange Commission in 2016. There's interest in how the new administration could impact enforcement as...more
After a relatively slow year of Foreign Corrupt Practices Act (FCPA) prosecutions in 2015, this year started out with a landmark settlement against telecommunications provider VimpelCom Ltd. DC Partner Mark Srere, Denver...more
Welcome to Dorsey & Whitney’s monthly Anti-Corruption Digest. In this digest, we draw together news of enforcement activity throughout the world and aim to reduce your information overload. Our London, Minneapolis, New York...more
1. Criminal Division AAG Promises Increased Transparency in Corporate Charging Decisions. In an April 17, 2015 speech at New York University Law School’s Program on Corporate Compliance and Enforcement, Leslie Caldwell,...more
In this episode I visit with the FCPA Professor over some of his observations from the 2014 FCPA year just pass. We discuss the Esquenazi decision, Opinion Releases and several enforcement actions. ...more
In this episode, Compliance Week Editor-in-Chief Matt Kelly and I discuss the Avon and Alstom FCPA enforcement actions and then take a look at the ongoing Petrobras corruption scandal and what it means for Brazil. ...more
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
In this episode I begin a two-part review of the 2014 FCPA year. In this episode I review some of the significant corporate enforcement actions. ...more
The old expression goes – “Do not break your arm patting yourself on the back” – but maybe I might just extend my arm a little with the Alstom settlement. Last year I predicted that the Alstom case would eclipse Siemens as...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
The key to being a successful (FCPA) prognosticator is never to keep score. If you do, you are likely to be disappointed. Instead, I follow the strategy of calculated distraction – for example, I predicted last year...more
Porphyry is a type of stone that was much favored in the Roman world. In a review of several books in the New York Review of Books, entitled “The Purple Stone of Emperors”, Peter Brown looked into the history of the lithic in...more
We all like annual reviews and predictions for the upcoming year – it is a New Year’s rite of passage and one that brings perspective and a sense of order to our otherwise chaotic lives....more
In this episode 118, I take a deep dive into the Alstom FCPA enforcement action and its implication for the CCO and compliance practitioner. I also discuss comments from Dick Cassin and the FCPA Professor on the case. ...more
“It was important that we played our game for 90 minutes.” That line was found in a The Daily Telegraph article entitled “The unthinkable scoreline: Brazil 1, Germany 7” by Jeremy Wilson. It was a quote from Mats Hummels,...more