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Anti-Corruption Deferred Prosecution Agreements Enforcement Actions

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

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

Thomas Fox - Compliance Evangelist

FCPA Compliance Report - James Koukios on the Monaco Speech

In this episode of the FCPA Compliance Report, I am joined by fan-favourite James Koukios, a partner at Morrison and Foerster, and we take a deep dive into the Lisa Monaco speech from October and related remarks from other...more

Dechert LLP

Nouvelle réforme des lois anti-corruption en France : Les temps changent (de nouveau !)

Dechert LLP on

Il y a presque cinq ans, la France a promulgué sa loi anti-corruption, dite loi Sapin II. Cette loi, considérée comme disruptive à l'époque, a introduit des innovations importantes, y compris la possibilité pour les...more

Dechert LLP

Reforming France’s Anti-Corruption Laws: Times are Changing (Again!)

Dechert LLP on

Almost five years ago, France enacted its anti-corruption legislation, Sapin II. The law was considered ground-breaking at the time and introduced a number of important innovations, including the ability for companies to be...more

The Volkov Law Group

DOJ and SEC Announce First Corporate FCPA Settlement for 2021: Amec Foster Wheeler, a Wood Group Subsidiary, Agrees to Pay over...

The Volkov Law Group on

The Justice Department and the Securities Exchange Commission are back in business.  The first corporate FCPA enforcement action in 2021 came after a six-month hiatus in 2021.  While many commentators sought to read the...more

Faegre Drinker Biddle & Reath LLP

Growing International Coordination of Multi-jurisdictional FCPA Enforcements

In remarks at the American Conference Institute’s 37th International Conference on the Foreign Corrupt Practices Act (FCPA) on December 3, 2020, Gen. Brian C. Rabbit, then acting assistant attorney general of the U.S....more

The Volkov Law Group

Vitol Pays $163.7 Million to Settle FCPA Case (Part I of III)

The Volkov Law Group on

The Justice Department continues to produce FCPA resolutions in a record year for enforcement.  The latest, and perhaps the beginning of several end-of-year and end of the Trump Administration resolutions, is DOJ’s settlement...more

A&O Shearman

Woefully inadequate anti-bribery measures lead to deferred prosecution agreement for aircraft refurbishment company

A&O Shearman on

The SFO has concluded a deferred prosecution agreement with Airline Services Limited (ASL), a UK supplier of aircraft cabin parts and services, for failure to prevent bribery under s7 Bribery Act 2010.  Despite the company...more

Kilpatrick

Ending the Decade on a High: U.S. Government’s 2019 FCPA Enforcement Highlights

Kilpatrick on

The U.S. Government’s 2019 FCPA enforcement efforts led to new milestones; further cooperation with international authorities; and continued use of independent corporate monitors.  The following are key takeaways of these...more

Latham & Watkins LLP

Much-Awaited Clarifications on the French Deferred Prosecution Agreement

Latham & Watkins LLP on

The French National Financial Prosecutor and the French Anticorruption Agency have released guidelines on the French deferred prosecution agreement, that offers a few welcome clarifications. After years of debate on the...more

Jones Day

Official Guidance Clarifies Eligibility Requirements for "French DPAs" in Corruption-Related Matters but Raises Key Questions -...

Jones Day on

The Financial Public Prosecutor and the French Anticorruption Agency ("FAA") have recently adopted guidelines on the implementation of the "convention judiciaire d'intérêt public" ("CJIP"), the French version of a deferred...more

Kramer Levin Naftalis & Frankel LLP

Les premières lignes directrices communes PNF/AFA

Lorsque la loi n° 2016-1691 du 9 décembre 2016 (« Loi Sapin II ») a créé la convention judicaire d’intérêt public (« CJIP ») sur le modèle des transactions pénales américaines (Deferred Prosecution Agreement ou « DPA »), on a...more

Dechert LLP

Navigating French Internal Investigations and Self-Reporting - French Authorities Issue New Guidance

Dechert LLP on

France is off to a strong start enforcing Sapin II, its December 2016 anti-corruption legislation. Since the enactment of the statute, the lead French investigating and prosecuting agencies, the Parquet National Financier...more

A&O Shearman

Anti-Bribery and Corruption Year in Review: 2018

A&O Shearman on

Global developments in anti-bribery and corruption regulation, compliance and enforcement - Welcome to the 2018 edition of Allen & Overy’s annual publication covering global developments in anti-bribery and corruption...more

Latham & Watkins LLP

Global Legal Insights: Bribery & Corruption, 6th Edition – China

Latham & Watkins LLP on

Brief overview of the law and enforcement regime - China has had strong anti-corruption laws for many years. On 1 January 1980, the Criminal Law of the People’s Republic of China (the “PRC Criminal Law”), containing the...more

Thomas Fox - Compliance Evangelist

The NPA; The Petrobras FCPA Enforcement Action: Part III

This blog post concludes my multi-part exploration of the Petróleo Brasileiro S.A. – Petrobras (Petrobras) Foreign Corrupt Practices Act (FCPA) enforcement action. Today we consider the stunning result achieved by Petrobras –...more

Thomas Fox - Compliance Evangelist

Sherlock Holmes Week-Part V: The Empty House and Imagination

This week I have returned to one my favorite themes for every Chief Compliance Officer (CCO), compliance professional and compliance program: Sherlock Holmes. ...more

Jones Day

France Takes Next Step in Anticorruption Enforcement: First "French DPAs" and What Companies Should Know

Jones Day on

The Situation: Anticorruption legislation passed by French lawmakers in 2016 authorizes the resolution of a corruption matter by means of a "convention judiciaire d'intérêt public" ("CJIP"), the French version of a deferred...more

BCLP

What enforcement tools are in the armoury of prosecutors in the US, UK and France?

BCLP on

Summary: Deferred prosecution agreements have been widely used by US prosecutors since the early 2000s. Prosecutors in the UK and France only obtained this power in 2014 and 2016 respectively – but they are making up for...more

Hogan Lovells

Global bribery and corruption outlook 2018

Hogan Lovells on

For the most part, 2018 will see countries do more to enforce their anti-bribery and corruption laws. How authorities plan to do this — from cooperating with foreign counterparts to adapting others' regimes — differs by...more

Skadden, Arps, Slate, Meagher & Flom LLP

The Sapin II Act: New Perspectives on Cross-Border Investigations

On November 30, 2017, the Institut des Hautes Etudes sur la Justice (IHEJ) and Skadden hosted a roundtable at the Cercle de l’Union Interalliée in Paris to discuss new perspectives on the Sapin II Act and cross-border...more

Robinson+Cole Manufacturing Law Blog

Settlement with Swedish Telecom Giant Falls Just Short of First $1 Billion FCPA Resolution

In September, the U.S. government announced a nearly $1 billion FCPA (Foreign Corrupt Practices Act) settlement with the Swedish telecommunications company Telia. The total monetary payment in this global resolution makes it...more

Skadden, Arps, Slate, Meagher & Flom LLP

Government Enforcement Investigations – What You Need to Know in 2018

On October 4, 2017, Skadden presented the seminar “Government Enforcement Investigations – What You Need to Know in 2018.” Skadden partners Ryan Junck and Elizabeth Robertson, both based in London, moderated the panel...more

Thomas Fox - Compliance Evangelist

The Telia FCPA Resolution: Part V-Lessons Learned

Today, lessons learned. Over the past several blog posts, I have taken a deep dive into the Telia Company AB (Telia) Foreign Corrupt Practices Act (FCPA) enforcement action. Anytime you have new No. 1 in the all-time FCPA...more

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