Anti-Corruption Securities & Exchange Commission

News & Analysis as of

What the Government Expects to Find in an Anti-Corruption Compliance Program

Similar to Foreign Corrupt Practices Act enforcement generally, the federal government has expanded what it expects to find in an anti-corruption compliance program. U.S.-connected companies operating internationally...more

Whistleblowing: An Employer’s Guide To Global Compliance

In This Issue: - Foreword - A Summary Across Five Continents - Law and Sanctions - The Legislative Framework: Whistleblower Protections Across the Globe - Global Differences: The Cultural...more

Pink Flamingos and the Compliance Audit

The creator of one of the most ubiquitous symbols of mid-century Americana died earlier this week. Don Featherstone, the creator of the pink plastic lawn flamingo, the ultimate symbol of American lawn kitsch, has died. He was...more

Tribute to John David Crow and an Innovation Strategy for Your Compliance Program

John David Crow died Wednesday. Until Johnny Football, he was the only football player from Texas A&M University to win the Heisman Trophy. He played under the legendary Paul ‘Bear’ Bryant at A&M and for all of Bryant’s...more

Major Recent Developments in International Anti-Corruption

There have been some significant developments in the world of international anti-corruption laws in recent months. The following are a few examples...more

Are your sponsorship and hospitality controls enough to satisfy the FCPA? Maybe not

On May 20, 2015, the US Securities & Exchange Commission (SEC) settled an administrative proceeding with global mining /commodities producer BHP Billiton, resolving allegations that the company violated the books and records...more

May FCPA Compliance Digest | Interactive, Engaging FCPA Training from the Start

You’ve been reading the FCPA Compliance Digest for five months now, and there’s still not a shortage of companies getting into trouble for violating the FCPA. That may seem like an obvious statement, but running out of news...more

SMEs Face Big Risks without Effective Anti-Corruption Compliance Programs

Over the past year, the highest profile Foreign Corrupt Practices Act (FCPA) enforcement actions involved very large multinational companies (MNCs) paying very large fines: Alstom ($772 million fine), ALCOA ($384 million),...more

Economic Downturn Week, Part III – The Desktop Risk Assessment

I continue my exploration of actions you can take to improve your compliance program during an economic downturn with a review of what my colleague Jan Farley, the Chief Compliance Officer (CCO) at Dresser-Rand, called the...more

Economic Downturn Week, Part I – Mapping of Your Internal Compliance Controls

This week I will present a series on steps that you can take in your compliance program if you find yourself, your company or your industry in an economic downturn. All of the recommendations I will make are ideas that have...more

Preventing the Worst: Stopping Obvious and Bold FCPA Violations by Executives

Last year, a number of corruption cases, both individual prosecutions and suits against companies, revolved around the behavior of senior executives. While third parties can often be the vehicle companies use to funnel bribe...more

FinCrimes Update - April 2015 Summary, Volume 2, Issue 4

OFAC FINES PAYMENT PROCESSING COMPANY FOR PROVIDING SERVICES TO A DESIGNATED NARCOTICS TRAFFICKER - On April 15, OFAC entered into a $23,336 settlement with an Atlanta-based payment processing company for its role in...more

Top Ten International Anti-Corruption Developments for April 2015

1. Criminal Division AAG Promises Increased Transparency in Corporate Charging Decisions. In an April 17, 2015 speech at New York University Law School’s Program on Corporate Compliance and Enforcement, Leslie Caldwell,...more

FinCrimes Update - February 2015 Summary, Volume 2, Issue 2

NEW YORK BANK REGULATORY CONSIDERING CYBERSECURITY REGULATIONS, RANDOM AUDITS OF BANKS - On February 25, New York DFS Superintendent Benjamin Lawsky delivered remarks at Columbia Law School focusing on how state bank...more

Top Ten International Anti-Corruption Developments for February 2015

This installment of MoFo’s Top Ten International Anti-Corruption Developments highlights a number of significant domestic and global anti-corruption enforcement developments for busy in-house counsel and compliance...more

This Week In Securities Litigation

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

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

Top Ten International Anti-Corruption Developments for November 2014

For busy in-house counsel and compliance professionals, we have tried to summarize the most important international anti-corruption developments in the past month with links to primary resources. November was definitely a...more

Beyond the Checklist: Seven Keys to Effective Trade Due Diligence

Anti-corruption due diligence can be vexing even in the best of conditions; it is often made more complicated by time and business pressures that arise in the context of a merger or acquisition or an urgent sales opportunity....more

Management of Corruption Risks – Business Lessons from GSK

The Department of Justice (DOJ) and Securities and Exchange Commission (SEC) have made it abundantly clear over the past several years that companies should assess their risk and then manage their own risks....more

The 10 Essential Steps to Implement an Effective Anti-Corruption Compliance Program [Video]

The Department of Justice's and the SEC's FCPA Guidance issued last November, 2012, outlined the hallmarks of an "effective" anti-corruption compliance program. In the FCPA Guidance, the Justice Department and the SEC...more

Integrating and Training Your Agents and Distributors (Part II of IV)

The Department of Justice and the SEC know they can push companies to expand and improve their anti-corruption compliance programs. They are well aware that the requirements set forth in their settlement documents, as well as...more

Fine Tuning Your Anti Corruption Compliance Program [Video]

In this era of aggressive FCPA enforcement, companies are adopting anti-corruption compliance programs. The Department of Justice and the SEC have warned companies against adopting "paper compliance programs" without...more

Building an Anti Corruption Compliance Program Practical Steps 2 18 14, 9 02 AM [Video]

Companies face many risks in the anti-corruption enforcement arena. With the growing globalization of anti-corruption enforcement, companies are responding quickly by enhancing their anti-corruption compliance...more

Tailoring Your Anti Corruption Program to a Risk Assessment [Video]

The Department of Justice and the SEC have emphasized the importance of designing an anti-corruption compliance program based on a company's risk assessment. An effective program has to be tailored to the specific risks...more

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