The Line Between Gift Giving and Bribery
The New Cold War: Risk, Sanctions, Compliance Episode 21: "Interview with Drago Kos of the OECD Working Group on Bribery"
Dr. Jan Spafke and Jad Mhanna on Compliance in Non-Western Cultures
Corruption, Crime & Compliance - Episode 208 - A Deep Dive into the WPP FCPA SEC Settlement
Anti-Corruption Compliance and Enforcement Trends in the US and Globally
Doing Business in the European Union | Global Laws & Compliance Program
Gary Kalman on Corruption and Compliance Programs
Integrity Matters: Assessing the Corporate Compliance Climate in 2021-Anti-Bribery and Anti-Corruption Enforcement in 2021
Compliance Perspectives: Risk and the 2020 Compliance & Ethics Institute
Applying Behavioral Science to Compliance – A Conversation with Richard Bistrong, Front-Line Anti-Bribery LLC
Episode 119 -- The Ericsson FCPA Settlement
FCPA Compliance Report-Episode 346, Mike Skopets on Miller’s Summer 2017 FCPA Report
FCPA Compliance Training That's About the 'What Happens' at the Front-lines
FCPA Compliance Report-Episode 329, James Koukios
FCPA Compliance Report-Episode 302-Carlos Ayers on the Odebrecht Settlement from Brazil
How Can We Develop Anti-Bribery Ambassadors?
Joe Spinelli on the Kroll-Ethisphere Anti-Bribery & Corruption Report
Anti-Bribery and Compliance Challenges Ahead
What is the Current State of Anti-Bribery Compliance & Enforcement in Australia?
FCPA Compliance and Ethics Report-Episode 149-Patrick Taylor of Oversight Systems on developments in transaction monitoring
On December 22, 2023, President Biden signed into law the 2024 National Defense Authorization Act. This bipartisan legislation included the Foreign Extortion Prevention Act (FEPA), which enables criminal prosecution of...more
On December 14, 2023, Congress passed the Foreign Extortion Prevention Act (“FEPA”) in an effort to address certain deficiencies inherent in the current iteration of the Foreign Corrupt Practices Act (“FCPA”), as part of the...more
Background Note: In their analysis of the Foreign Corrupt Practices Act (FCPA), Adam Rouse, Vazantha Meyers, and Ashish Prasad emphasize the crucial role of robust compliance programs in minimizing liability associated with...more
The Foreign Corrupt Practices Act (FCPA), 15 U.S.C. §§ 78dd-1, et seq was signed into law in 1977 by President Jimmy Carter. The FCPA generally prohibits payments to foreign government officials in order to obtain or retain...more
Companies with business operations in Japan should review due diligence procedures and internal policy regarding small facilitation payments to ensure they are consistent with new guidance from METI. In May 2021, the...more
The year 2020 witnessed a record level of $2.78 billion in corporate fines and penalties from enforcement of the Foreign Corrupt Practices Act (FCPA) by the U.S. Department of Justice (DOJ) and the U.S. Securities and...more
On October 1, 2020, the new Instruction on the Investigation and Prosecution of Foreign Corruption for the Dutch Public Prosecution Service ("DPPS") entered into force, indicating certain factors that play a role in...more
Eddie Van Halen died yesterday. He is the first rocker, more or less, of my generation to die after the age of 60. He was also one of the greatest guitarists ever. Indeed, I would rank him as the best guitarist of his...more
We rarely have seen a single Foreign Corrupt Practices Act (FCPA) enforcement action generate so many individual criminal pleas. The Sargeant Marine Inc. (Sargeant Marine) case is an exception. To date, there have been six...more
...On July 3, the Department of Justice (“DOJ”) and the Securities and Exchange Commission (“SEC”) published the Second Edition of A Resource Guide to the U.S. Foreign Corrupt Practices Act. A link to the Second Edition is...more
Barclays joined the club of global financial institutions settling FCPA violations for hiring of relatives of foreign officials in Asia. Barclays agreed to disgorge $3.8 million and paid prejudgment interest of nearly $1...more
2017 marked the fortieth anniversary of the Foreign Corrupt Practices Act (FCPA), and showed continued robust enforcement against both individuals and companies by the U.S. Department of Justice (DOJ) and the U.S. Securities...more
Issue-Spotting and Compliance Best Practices - An understanding of the Foreign Corrupt Practices Act (FCPA) and Corruption of Foreign Public Officials Act (CFPOA) provides a framework to consider how, when and why these...more
At the 34th International Conference on the Foreign Corrupt Practices Act held last week in Washington, D.C., industry executives, members of the defense bar, and regulators examined developments in the enforcement of the...more
New York-based hedge fund Och-Ziff Capital Management Group (the “Hedge Fund”) agreed to pay approximately $412 million to resolve charges brought by the U.S. Securities and Exchange Commission (“SEC”) and Department of...more
Busy Q1 Yields Several Significant FCPA Resolutions - Overview - On February 19, during the US Securities and Exchange Commission’s (SEC) annual “SEC Speaks” conference, Kara Brockmeyer, Chief of the SEC’s FCPA...more
Earlier this week, the Securities and Exchange Commission (SEC) announced resolution of a Foreign Corrupt Practices Act (FCPA) enforcement action involving the Hitachi Ltd (Hitachi). There were several interesting aspects to...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
No Dog Days of August for the SEC—A Recap of a Busy Month - Why it matters: Who says there is a government slowdown in August? Not for the SEC. August 2015 turned out to be very busy indeed for the agency, which...more
Violations of the Foreign Corrupt Practices Act (“FCPA”) can lead to hefty penalties. Indeed, individuals who violate the FCPA, and their employers, could be on the hook for a variety of penalties described below. Companies...more
Intuitively, Israeli companies and their directors would likely assume that their businesses are immune to investigation and the assessment of penalties by US regulators that are separated by a vast ocean and located more...more
On June 1, 2015, Canada’s Extractive Sector Transparency Measures Act (“ESTMA” or “the Act”) came into force. Approved in December 2014, but not in force until this month, the Act requires companies in the extractive sector...more
Moe Green died again yesterday but this time he was not shot through the glasses, it was from cancer and the fictional Las Vegas mobster lived to the ripe old age of 79. Of course I am referring to “Alex Rocco, the veteran...more
In this issue: - FCPA AT A GLANCE - THE ANTI-BRIBERY PROVISIONS OF THE FCPA - TO WHOM THE ANTI-BRIBERY PROVISIONS APPLY - THE PAYMENT ELEMENT - THE CORRUPT INTENT ELEMENT - WHO IS A...more
The recent enforcement of Chinese anti-bribery laws against British pharmaceutical company GlaxoSmithKline (GSK) highlights the compliance challenges faced by foreign companies operating in China....more