News & Analysis as of

Anti-Corruption Corporate Misconduct

Society of Corporate Compliance and Ethics...

[Virtual Event] Compliance & Ethics Essentials Workshop - December 2nd - 5th, 8:00 am - 5:00 pm CT

Learn the key principles of compliance - no travel required! If you’re new to or have minimal experience in compliance management don’t miss this opportunity to build the foundational knowledge you need! SCCE’s four-day...more

The Volkov Law Group

Tracking FCPA Individual Enforcement

The Volkov Law Group on

While FCPA enforcement against companies has been relatively quiet this year, despite a strong beginning to the year — the SAP case for $220 million; and the Gunvor case for $661 million — DOJ has been pushing a number of...more

Skadden, Arps, Slate, Meagher & Flom LLP

DOJ Launches Corporate Whistleblower Awards Pilot Program and Announces a New Incentive for Self-Reports

On August 1, 2024, the Department of Justice’s Criminal Division launched the Corporate Whistleblower Awards Pilot Program (the Program), following up on its announcement in March 2024 of a plan to offer whistleblower awards....more

Bracewell LLP

Digging for Trouble: The Double-Edged Sword of Decisions to Report Misconduct

Bracewell LLP on

On May 10, 2024, Romy Andrianarisoa, former Chief of Staff to the President of Madagascar, was convicted for soliciting bribes from Gemfields Group Ltd (Gemfields), a UK-based mining company specializing in rubies and...more

NAVEX

The Supreme Court Made Its Rulings; Corporate Compliance Needs March On

NAVEX on

At the end of June, the U.S. Supreme Court issued major decisions on the enforcement power of the Securities and Exchange Commission, what does or doesn’t qualify as a bribe of government officials, and on federal judges’...more

Society of Corporate Compliance and Ethics...

[Virtual Event] Compliance & Ethics Essentials Workshop - August 5th - 8th, 8:00 am - 5:00 pm CT

Learn the key principles of compliance - no travel required! If you’re new to or have minimal experience in compliance management don’t miss this opportunity to build the foundational knowledge you need! SCCE’s four-day...more

Skadden, Arps, Slate, Meagher & Flom LLP

Decoding AFA’s Guide: A Comparison of Sponsorship and Charitable Donations in France, the US and the UK

On March 26, 2024, the French Anti-Corruption Agency (AFA) published a guide on how to engage in corporate sponsorship and charitable donation activities while appropriately mitigating corruption risks (the Guide)...more

Skadden, Arps, Slate, Meagher & Flom LLP

DOJ Pilot Program Promises Non-Prosecution Agreements to Individuals Reporting Fraud, Bribery and Other Corporate Crimes

On April 15, 2024, the Department of Justice’s (DOJ’s) Criminal Division unveiled a new Pilot Program on Voluntary Self-Disclosures for Individuals that offers non-prosecution agreements (NPAs) to individuals who voluntarily...more

Benesch

White Collar Quarterly Report | Q1 2024

Benesch on

We are thrilled to introduce the inaugural issue of our quarterly White Collar newsletter, a dedicated resource from Benesch’s White Collar, Government Investigations & Regulatory Compliance Practice Group. Each issue...more

Thomas Fox - Compliance Evangelist

The Trafigura FCPA Enforcement Action – Part 1 – Introduction

In March 2024, the Department of Justice (DOJ) announced the resolution of a Foreign Corrupt Practices Act (FCPA) enforcement action involving the Swiss trading firm G Trafigura Beheer B.V. (Trafigura), an international...more

Thomas Fox - Compliance Evangelist

The Gunvor FCPA Enforcement Action: Part 3-the Discounted Fine

We continue our exploration of the resolution of the FCPA enforcement action involving the Swiss trading firm Gunvor S.A. The enforcement action came in with a $661 million penalty against the company, which has pleaded...more

Adams and Reese LLP

Beyond Borders: Navigating Global Business Compliance with the FCPA

Adams and Reese LLP on

On March 7th, the Department of Justice (DOJ) announced a new whistleblower reward program intended to help prosecutors bring more foreign corruption cases. Under the new program, individuals who report corporate misconduct...more

Thomas Fox - Compliance Evangelist

Ten Top Lessons from Recent FCPA Settlements-Lesson No. 3, Extensive Remediation

Over the past 15 months the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) has made clear through three Foreign Corrupt Practices Act (FCPA) enforcement actions and speeches, their priorities in...more

Kohn, Kohn & Colapinto LLP

Vatican Recognizes Importance of Financial Whistleblowers, But Offers No Anonymity

In January, the Vatican issued new procedures on whistleblowing, expanding on 2019 procedures for reporting financial anomalies to the Office of the Auditor General. The new procedures are a recognition of the importance of...more

Society of Corporate Compliance and Ethics...

[Virtual Event] Compliance & Ethics Essentials Workshop - May 13th - 16th, 9:00 am - 3:00 pm CT

SCCE’s four-day Compliance & Ethics Essentials Workshop provides comprehensive education on the core elements of a compliance program in a convenient virtual format. The curriculum is ideal for those new to or with little...more

Dentons

Ep. 2 - Why Anonymous Reporting is the Cornerstone of Your Compliance Program

Dentons on

When was the last time your organization received an anonymous compliance concern?  Has it been so long you can’t recall? Maybe you consider yourself lucky that the organization has never received a concern on your watch, or...more

The Volkov Law Group

Top Compliance Reminders from 2023 FCPA Enforcement

The Volkov Law Group on

While 2023 was a relatively slow year in FCPA enforcement, the DOJ and SEC settlements announced throughout the year set out a list of important ethics and compliance reminders. While these may seem obvious to everyone, I...more

Thomas Fox - Compliance Evangelist

Leadership’s Conduct at the Top

The 2022 Monaco Memo emphasized the basic point that the key to every company is culture. The bottom line is that corporate culture matters and corporate culture that fails to hold individuals accountable, or fails to invest...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

Kohn, Kohn & Colapinto LLP

Despite Record Year, SEC Must Improve Whistleblower Program to Align with White House Anti-Corruption Initiative

SEC Chair Gary Gensler announced on October 25th that in the 2023 fiscal year, the Commission received a record number of 18,000 whistleblower tips. The SEC Whistleblower Program has grown rapidly and effectively since its...more

Thomas Fox - Compliance Evangelist

How the Venetian Republic Invented the Modern Hotline-Into the Lion’s Mouth

It turns out that Venice invented the modern hotline reporting system with their Lion’s Mouth reporting protocol. The symbol of Venice is the Lion St. Mark. The use of this symbol has led to the maxim straight from the lion’s...more

ArentFox Schiff

Show Me the Money: Using Compensation Structures to Promote Compliance

ArentFox Schiff on

Recent guidance from the US Department of Justice (DOJ) reflects its continued focus on corporate compensation structures to promote compliance. In the past few months, the DOJ has entered into settlement agreements that...more

The Volkov Law Group

DOJ’s Latest Opinion Release Underscores Absence of Corrupt Intent and Lack of Business Purpose

The Volkov Law Group on

The Justice Department has had a slow year in FCPA enforcement (another profound grasp of the obvious).  The reasons for this may be a question of timing elements in the pipeline of cases....more

The Volkov Law Group

The Evolution of the Compliance Profession

The Volkov Law Group on

One of the benefits of old(er) age is perspective and experience.  (As we age, we have to find the positive reasons to tout).  If there is one thing (of many) the compliance profession has demonstrated, it is that compliance...more

Thomas Fox - Compliance Evangelist

DAG Monaco on Cooperation and Compliance Incentives for M&A

Early in October at the 2023 SCCE Compliance and Ethics Institute, Deputy Attorney General Lisa Monaco delivered a long-anticipated speech expanding and formalizing the Department of Justice’s (DOJ’s) new Safe Harbor for...more

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