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Anti-Corruption Federal Sentencing Guidelines

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)

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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

Society of Corporate Compliance and Ethics...

The Sentencing Guidelines at Thirty

The Organizational Sentencing Guidelines have turned thirty, and what began as an experiment is now an established framework for compliance programs in the US and around the globe. To commemorate the milestone, the United...more

Bracewell LLP

DOJ Issues New Policy Encouraging Self-Reporting FCPA Violations

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On November 29, 2017 the Deputy Attorney General of the U.S. Department of Justice (DOJ), Rod J. Rosenstein, announced a new FCPA enforcement policy that seeks to incentivize voluntary self-reporting by providing companies...more

Bradley Arant Boult Cummings LLP

DOJ’s FCPA Corporate Enforcement Policy Creates Greater Certainty for Companies

The Foreign Corrupt Practices Act of 1977 (FCPA) makes it unlawful for certain classes of persons and entities to make payments to foreign government officials to assist in obtaining or retaining business. On November 29,...more

Jones Day

DOJ's New FCPA Enforcement Policy Continues its "Carrot-and-Stick" Approach

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The Situation: Companies that learn of Foreign Corrupt Practices Act ("FCPA") violations by employees or agents are faced with significant uncertainty as to whether the benefits and risks of self-disclosing the conduct to the...more

Thomas Fox - Compliance Evangelist

This Week in FCPA-Episode 55, the Covfefe Edition

This week, Jay and I have a wide-ranging discussion on some of the week’s top compliance related stories. We discuss: 1. Brazilian meatpacker JBS agrees to the largest fine ever for fine for bribery and corruption, $3.2bn...more

Jones Day

Department of Justice Fraud Section Provides Guidance on Evaluating Corporate Compliance Programs

Jones Day on

On February 8, 2017, the United States Department of Justice ("DOJ") Fraud Section published a blueprint for assessing corporate compliance efforts, titled "Evaluation of Corporate Compliance Programs" ("Guidance"). It...more

Robins Kaplan LLP

Insight from the DOJ Fraud Section

Robins Kaplan LLP on

Without fanfare, on February 8 the Fraud Section of the Department of Justice (DOJ) published new corporate compliance guidance on its public website. The guidance is presented as a set of topics and questions, entitled...more

Thomas Fox - Compliance Evangelist

Compliance Isn’t Going Away (and neither should you) – Part I

Yesterday I presented my views on why I believe that Foreign Corrupt Practices Act (FCPA) enforcement will continue under the new administration. Today, I want to begin a multi-part series (sorry I don’t know how long it will...more

Thomas Fox - Compliance Evangelist

Hallmark 5-Communications and Training

I. Training - The communication of your anti-corruption compliance program is something that must be done on a regular basis to ensure its effectiveness. The FCPA Guidance explains, “Compliance policies cannot work...more

Thomas Fox - Compliance Evangelist

LATAM/LAN FCPA Enforcement Action: Part II – Some Observations

Yesterday I reviewed the underlying facts of the long running Foreign Corrupt Practice Act (FCPA) matter involving the LATAM Airlines Group S.A. (LATAM). The resolution involved criminal charges detailed in an Information...more

Dorsey & Whitney LLP

Dorsey Anti-Corruption Digest - April 2016

Dorsey & Whitney LLP on

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

The Volkov Law Group

New and Important Compliance Standards in DOJ’s Recent FCPA Guidance (Part II of II)

The Volkov Law Group on

The importance of DOJ’s hiring of Hui Chen as Compliance Counsel was recently confirmed by DOJ’s release of new compliance remediation standards for FCPA compliance programs. DOJ has, once again, raised the bar on FCPA...more

NAVEX

Top Ten Ethics & Compliance Predictions & Recommendations for 2016

NAVEX on

To help with our predictions and recommendations, we’ve talked with industry experts, our colleagues at NAVEX Global, and ethics and compliance professionals from our more than 12,500 client organizations. Based on their...more

Foley & Lardner LLP

The High Cost of an FCPA Violation

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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

Thomas Fox - Compliance Evangelist

Code of Conduct, Compliance Policies and Procedures-Part I

For the remainder of this week, I will have a four-part episode on your Code of Conduct and anti-corruption compliance policies and procedures. In today’s post I will review the underlying legal and statutory basis for the...more

Thomas Fox - Compliance Evangelist

FCPA Compliance and Ethics Report-Episode 30-Interview with the FCPA Professor-Part 2

This episode 30 is Part 2 of my interview with the FCPA Professor. ...more

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