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Anti-Bribery Department of Justice (DOJ) Corruption

Littler

Robust Action Helps Recidivist Employer Reduce Penalty for Alleged Bribery in South Africa and Indonesia

Littler on

In the first major action of 2024, the Department of Justice (DOJ) announced it had entered into a three-year deferred prosecution agreement (DPA) with a publicly traded global software company for alleged violations of the...more

Jones Day

FCPA 2023 Year in Review

Jones Day on

Foreign Corrupt Practices Act (“FCPA”) enforcement continues to slowly rebound from pre-pandemic levels. In 2023, the Department of Justice (“DOJ”) and the Securities and Exchange Commission (“SEC”) resolved 13 corporate FCPA...more

Thomas Fox - Compliance Evangelist

The SAP FCPA Enforcement Action-Part 3: The Comeback

This week we are taking a deep dive into the SAP Foreign Corrupt Practices Act (FCPA) enforcement action. In it, SAP agreed to pay the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) approximately...more

The Volkov Law Group

SAP’s Bribery Schemes — Systemic Corruption Around the Globe (Part II of III)

The Volkov Law Group on

When it comes to FCPA enforcement and expectations, DOJ has moved the goalposts.  Some would argue that DOJ has been consistent all along.  The truth, like most issues, lies somewhere between the extremes....more

The Volkov Law Group

DOJ and CFTC Close Out Slow FCPA Enforcement Year with $98 Million Resolution with Freepoint Commodities LLC (Part I of II)

The Volkov Law Group on

The Justice Department’s FCPA enforcement record for 2024 was slow.  This  trend was unexpected, contrary to my own predictions and of various other prognosticators.  It is hard to explain why this slowdown occurred....more

Thomas Fox - Compliance Evangelist

What 2023 Brought to Compliance

2023 was a very significant year for every compliance practitioner and compliance program. While there was a paucity of corporate enforcement actions under the Foreign Corrupt Practices Act (FCPA), there were significant...more

Hogan Lovells

Key takeaways from the 40th ACI International Conference on the FCPA

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Last week at the 40th American Conference Institute (ACI) International Conference on the FCPA, government enforcement agencies such as the Department of Justice (DOJ), Securities and Exchange Commission (SEC), and UK Serious...more

Ballard Spahr LLP

DOJ Bolsters International Cooperation to Combat Corruption

Ballard Spahr LLP on

Summary - The Department of Justice (DOJ) has created the International Corporate Anti-Bribery initiative (ICAB), which aims to strengthen the United States’ global efforts in combating corruption through enhanced...more

Littler

Proper Planning and Swift Action Can Help Employers Avoid Foreign Corrupt Practices Act Prosecution

Littler on

While the Department of Justice (DOJ) has initiated at least two new Foreign Corrupt Practices Act (FCPA) enforcement actions against U.S. companies, it has also announced several decisions not to prosecute—most recently...more

Morgan Lewis

Anti-Bribery And Corruption Survey Report

Morgan Lewis on

Survey: Tech gaps, third parties pose biggest ABAC threats - Compliance professionals surveyed regarding their anti-bribery and corruption efforts (ABAC) indicated resource support deficiencies in areas including staffing...more

A&O Shearman

Corficolombiana Pays $80M To Resolve Bribery Probes

A&O Shearman on

On August 10, 2023, the U.S. Securities Exchange Commission (“SEC”) and the Department of Justice (“DOJ”), in coordination with Columbian authorities, announced that Colombian conglomerate Grupo Aval Acciones y Valores S.A...more

The Volkov Law Group

Ericsson Settles Breach of 2019 FCPA Deferred Prosecution Agreement: Agrees to Plead Guilty, Pay $206 Million, and Extend...

The Volkov Law Group on

Ericsson, a multinational telecommunications company, based in Sweden, settled its breach of its 2019 Deferred Prosecution Agreement, agreed to enter a guilty plea and pay a $206 million penalty.  In 2019, Ericsson entered...more

Jones Day

FCPA 2022 Year in Review

Jones Day on

Foreign Corrupt Practices Act (“FCPA”) enforcement has yet to rebound from the immediate pre-pandemic period. In 2022, DOJ and SEC resolved eight corporate FCPA matters for $878 million, including four resolutions coordinated...more

American Conference Institute (ACI)

[Event] Summit on Anti-Corruption & Compliance Programs - March 22nd - 23rd, Mexico City, Mexico

Hosted by American Conference Institute, the Mexico Summit on Anti-Corruption & Compliance Programs returns for another exciting year with curated programming that shines a global spotlight on anti-corruption compliance...more

WilmerHale

Global Anti-Bribery Year-in-Review: 2022 Developments and Predictions for 2023

WilmerHale on

While Foreign Corrupt Practices Act (FCPA) enforcement activity has not come close to returning to the heights seen a few years ago, 2022 reflected significant increases from the prior year in both the number of cases against...more

Thomas Fox - Compliance Evangelist

ABB FCPA Resolution: Part 1 – Introduction

Late last week, the Department of Justice (DOJ) announced a highly anticipated resolution of Foreign Corruption Practices Act (FCPA) violation involving the Swiss construction giant, ABB Ltd. The most obvious significance is...more

Oberheiden P.C.

Internal Audit for FCPA Compliance: A Detailed Guide

Oberheiden P.C. on

The Foreign Corrupt Practices Act (FCPA) (15 U.S.C. § 78dd-1 et seq.) is a federal anti-bribery law that makes it unlawful for certain people to pay foreign government officials in order to conduct business abroad. While it...more

Thomas Fox - Compliance Evangelist

Great Structures Week V – The Tacoma Narrows Bridge Failure and Preventing Failure in Your Compliance Program

I conclude my Great Structures Week with a focus on structural engineering failures: suspension bridges and the challenges of wind in their construction and maintenance. I am drawing these posts from The Great Courses...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for August 2022

Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption law and case developments from the past month,...more

Thomas Fox - Compliance Evangelist

Compliance Insights from Traliant: Scott Schneider, Spotlight on Anti-Corruption Training

Welcome to a special five-part blog post series on the New Traliant, sponsored by Traliant, LLC. Over this series, we have discussed what is new at the company and key issues that Traliant is helping to lead and define the...more

Thomas Fox - Compliance Evangelist

Compliance Insights from Traliant: Part 1 – John Arendes from Transforming Training From Boring to Brilliant

Welcome to a special five-part blog post series on the New Traliant, sponsored by Traliant, LLC. Over this series, we will discuss what is new at the company and key issues that Traliant is helping to lead and define the...more

McGuireWoods LLP

DOJ and SEC Kick Off the Second Quarter with Major FCPA Settlement with International Waste Management Company

McGuireWoods LLP on

On April 20, 2022, the U.S. Department of Justice (DOJ) and Securities and Exchange Commission (SEC) separately announced that Stericycle Inc. (Stericycle), an international waste management company headquartered in Lake...more

Morrison & Foerster LLP

2022 Predictions for Litigation, Investigations, and Enforcement Actions Affecting the Automotive Industry

Morrison & Foerster’s Automotive Task Force represents automotive industry clients in their most significant legal matters. We have tapped our multidisciplinary Automotive Task Force to get their opinions on what is likely...more

The Volkov Law Group

DOJ FCPA Opinion Letter Draws Lines Regarding “Corrupt Intent” and the “Business Purpose” Test

The Volkov Law Group on

Even with the absence of any major DOJ FCPA enforcement actions, DOJ issued an interesting FCPA Opinion Letter last week addressing application of the FCPA in circumstances where organizations face imminent serious bodily...more

Hogan Lovells

DOJ issues rare FCPA advisory opinion regarding the extortion exception

Hogan Lovells on

On January 21, 2022, the Department of Justice (“DOJ”) issued a Foreign Corrupt Practices Act (“FCPA”) Opinion Procedure Release (the “OPR” or “OPR 22-01”) addressing the rarely discussed extortion exception to the FCPA’s...more

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