News & Analysis as of

Anti-Corruption Securities & Exchange Commission

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

Update on Regulatory Compliance in the Global Health Care Industry

by Baker Ober Health Law on

A comprehensive understanding of the constantly evolving layers that make up federal anti-corruption statutes, sanctions regulations and export control restrictions is imperative for both the pharmaceutical and health care...more

What Can We Tell About the Trump Administration’s Focus on Compliance?

There are a few early signs that the Trump administration will continue to hold companies to the “way of compliance,” as our colleague Jane Lewis-Raymond put it recently on this blog. But after the first four months of his...more

Red Notice Newsletter - Chinese

ANTICORRUPTION DEVELOPMENTS - Steven Peikin Reported to Become Co-Director of SEC’s Enforcement Division - On May 26, 2017, The Wall Street Journal reported that recently confirmed Commissioner Jay Clayton will hire...more

Red Notice Newsletter - Russian

ANTICORRUPTION DEVELOPMENTS - Steven Peikin Reported to Become Co-Director of SEC’s Enforcement Division - On May 26, 2017, The Wall Street Journal reported that recently confirmed Commissioner Jay Clayton will hire...more

This Week in FCPA-Episode 55, the Covfefe Edition

by Thomas Fox on

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

Red Notice Newsletter - May 2017

ANTICORRUPTION DEVELOPMENTS - Steven Peikin Reported to Become Co-Director of SEC’s Enforcement Division - On May 26, 2017, The Wall Street Journal reported that recently confirmed Commissioner Jay Clayton will...more

Top Ten International Anti-Corruption Developments for April 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

FCPA Compliance Report-Episode 329, James Koukios

by Thomas Fox on

Today I have back with me James Koukios, partner and Morrison Foerster on the firm's March 2017 report on the Top Ten International Anti-Corruption Developments for the month. We highlight the 2nd Circuit Court of Appeals...more

The New Faces of FCPA Enforcement: The Transition to a Sessions-Clayton Enforcement Regime Is Unlikely to Result in Drastic...

by K&L Gates LLP on

Now that the Trump administration has passed its first 100 days, some additional insights are available with respect to how the administration plans to enforce anti-corruption laws, including the Foreign Corrupt Practices Act...more

The Foreign Corrupt Practices Act and the New Trump Administration: Your Top Ten Questions Answered

by Foley & Lardner LLP on

Since mid-2000s investigation of Siemens, and the resulting $800 million penalty for violations of the Foreign Corrupt Practices Act (FCPA), the FCPA has been an enforcement priority of the U.S. Government. Although a dip in...more

Day 8 of One Month to Better Compliance Through HR-Using Compensation to Operationalize Compliance

by Thomas Fox on

One of the areas that many companies have not paid as much attention to in their Foreign Corrupt Practices Act (FCPA) anti-corruption compliance programs is compensation. However the Department of Justice (DOJ) and Securities...more

Red Notice Newsletter - Chinese

Anticorruption Developments - Former Magyar Telekom Executives Reconcile Bribery Charges - April 24, 2017, the US Securities and Exchange Commission (SEC) announced that the Hungarian telecommunications company...more

Top Ten International Anti-Corruption Developments for March 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

Understanding the New DOJ Compliance Guidance: Part Three – Policies & Procedures

This is the third in a series of posts where we will explore critical elements of a successful compliance program. In February, the Department of Justice’s Fraud Section offered a new perspective on what the government...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

FCPA: 2016 Year in Review & 2017 Enforcement Predictions

by Bass, Berry & Sims PLC on

Bass, Berry & Sims announces the release of its "FCPA: 2016 Year in Review & 2017 Enforcement Predictions," a review of trends and developments in FCPA as well as a look ahead into what to expect for 2017. The newly released...more

Use of Social Media In a Best Practices Compliance Program

by Thomas Fox on

Why should you integrate social media into your compliance program? In a compliance program, a large portion of your consumers/customers are your employees. Social media presents some excellent mechanisms to communicate the...more

Signs, Signs, Everywhere a Sign: Changes in Store for SEC Enforcement under the Trump Administration

Even before President Trump’s nomination of Jay Clayton as the next Chairman of the Securities and Exchange Commission (“SEC” or “Commission”), signs have been appearing that changes are afoot within the Division of...more

The Global Corruption Corner: A Primer to the Foreign Corrupt Practices Act

by Blank Rome LLP on

Any company doing business abroad is subject to the long reach of the Foreign Corrupt Practices Act (“FCPA”). Small or privately-held companies, just like large or public companies, are subject to the criminal specter of the...more

Top Ten International Anti-Corruption Developments for January 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

Red Notice Newsletter - February 2017

Acting SEC Chief Limits Subpoena Authority to Enforcement Division Acting Director - On February 15, 2017,The Wall Street Journal reported that the acting Chair of the Securities and Exchange Commission (SEC), Michael...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

With New Guidance, DOJ Signals What Companies Should Expect to Answer During FCPA Inquiries

Without fanfare or forewarning, the US Department of Justice released new anti-corruption compliance guidance on February 8, 2017. The eight page document provides rare insight into the government’s evaluation of corporate...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

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