News & Analysis as of

Anti-Corruption Fraud

The PCAOB, Audits, and Compliance - Considerations for the Chief Compliance Officer

by Thomas Fox on

I recently had the chance to visit with Joe Howell, the Executive Vice President of Workiva LLC, to discuss, among other things, the function of the Public Companies Accounting Oversight Board (PCAOB) and what role it might...more

Top Ten International Anti-Corruption Developments for February 2017

by Morrison & Foerster LLP on

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 from the past month, with links to primary...more

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

by 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

Insight from the DOJ Fraud Section

by 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

First ‘Trial of the Century’ and the SQM FCPA Enforcement Action – Part II

by Thomas Fox on

Today I conclude my two-part series on the recent Foreign Corrupt Practices Act (FCPA) enforcement action involving the Chilean chemicals and mining company Sociedad Química y Minera de Chile (SQM), which agreed to pay a...more

Foreign Corrupt Practices Act 2016 Year-End Update

by BakerHostetler on

2016 was a record-setting year for Foreign Corrupt Practices Act (“FCPA”) enforcement, as both the U.S. Department of Justice (“DOJ”) and the U.S. Securities and Exchange Commission (“SEC”) recovered well over $2 billion in...more

The International Foreign Bribery Taskforce and the rise of international cooperation among anti-corruption authorities

by Dentons on

Recent events have called attention to the increasingly global nature of anti-corruption investigations and the rise in international cooperation among anti-corruption authorities. One such event involves the activities of...more

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

by Thomas Fox on

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

The Bribery Act: The changing face of corporate liability – International Hurdles

by White & Case LLP on

The Serious Fraud Office (SFO) can investigate companies operating both in the UK and overseas, prosecuting bribery wherever the offence takes place, but its efforts are frustrated by international obstacles to investigations...more

Wells Fargo Week: Part V – Compliance is the Answer

by Thomas Fox on

I want to end this week’s review of the Wells Fargo scandal by considering what is at issue and what is at stake in this imbroglio. Unlike a Foreign Corrupt Practices Act (FCPA) violation, Wells Fargo paid the relatively...more

Arrested Development: Fighting fraud & corruption in international aid

The following interview is with Oliver May. RB: Oliver, you’ve been specialising in how corruption affects aid organisations. Perhaps you could tell us a little about your background and how you got into that? OM:...more

Joe Howell on the PCAOB, Audits and Compliance – Part II

by Thomas Fox on

Today we have Part II of my exploration with Joe Howell about the PCAOB and how its work with public company auditors impacts anti-corruption compliance. I asked Howell about auditor rotation and what it means. Howell...more

Trust as a Fig-Leaf of Poor Compliance and Management

Trust is an important, nurturing presence in the workplace. There is a level of trust inherent in all controls, and NGOs are often dependent on trust, especially in emergency operations, distant field offices, and when...more

DOJ Fraud Section Retains Hui Chen as Compliance Counsel Expert

by Morgan Lewis on

Chen brings important industry experience to the role. The Department of Justice (DOJ) Fraud Section has retained Hui Chen as a “full-time compliance expert.” Ms. Chen comes to the position with compliance counseling...more

The World Bank: Lending & Developing without Corruption

The World Bank recently assessed a project relating to the funding of power stations in South Africa. The World Bank’s initial assessment appears to have cascaded from an SEC enforcement action with respect to Hitachi Ltd....more

Foreign Corrupt Practices Act 2015 Update

by BakerHostetler on

Despite a decline in enforcement actions by the Securities Exchange Commission (“SEC”) and the Department of Justice (“DOJ”), the first half of 2015 has continued to highlight the relevance and ever-evolving effects of the...more

HorrorFest 2015 Celebration I- The Films of Val Lewton and a Win for the DOJ

by Thomas Fox on

Today, October 2, is the first Friday in October so I begin my annual month of Friday HorrorFest Film highlights. This year I wanted to highlight the films of one of the great unknowns of horror films, Val Lewton. Lewton, a...more

DOJ Hires Compliance Counsel to Assist in Charging Decisions

by King & Spalding on

New Compliance Counsel Will Assess Effectiveness of Corporate Compliance Programs - Last week the U.S. Department of Justice (DOJ) revealed it is hiring a compliance counsel to assist DOJ prosecutors in assessing the...more

The New Canadian Integrity Regime: Compliance Carrots to Join the Debarment Sticks

Today we welcome Kristine Robidoux, Partner, Gowling Lafleur Henderson LLP, for an analysis of the new Canadian Integrity Regime. As Canada has one of the most robust Debarment regimes which includes anti-bribery enforcement,...more

International Fraud & Asset Tracing (3rd Edition), France

by Latham & Watkins LLP on

In this Guide: - Introduction - Managing the Internal Investigation - Disclosure from Third Parties - Steps to Preserve Assets/Documents - Civil Proceedings - Anti-Bribery/Anti-Corruption Legislation -...more

This Week In Securities Litigation

by Dorsey & Whitney LLP on

Four SEC Commissioners addressed the annual SEC Speaks Conference, reviewing recent agency initiatives and tracing potential paths for the future. The SEC also brought another FCPA action, a misappropriation case and an...more

Top Ten International Anti-Corruption Developments for January 2015

by Morrison & Foerster LLP on

This installment of MoFo’s Top Ten International Anti-Corruption Developments highlights important Department of Justice (DOJ) personnel changes, an increase in government resources being dedicated to FCPA enforcement...more

Anti-Corruption Campaign in China—Causes of Corruption, and Hope?

by Dorsey & Whitney LLP on

The following guest post is the first part of an occasional series on the anti-corruption campaign in China. The authors are resident in the Hong Kong office of Dorsey & Whitney LLP. SECactions welcomes submissions from other...more

Mitigating Bribery Risks With Financial Controls

by Michael Volkov on

Anti-corruption compliance is not as hard as it looks. In fact, by taking a step back, compliance professionals can gain insights. At the direction of compliance professionals, companies like to develop and adopt...more

UK SFO Drops High-Profile Corruption Case

by Morgan Lewis on

The trial of Victor Dahdaleh in London has collapsed due to the absence of key prosecution witnesses. The UK’s Serious Fraud Office (SFO) recently dropped its case against Victor Dahdaleh, the British-Canadian...more

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