Wicked Coin: The "Fat Leonard" Scandal
Corruption, Crime & Compliance: Deep Dive into The Gunvor FCPA Settlement
Episode 307 -- Sanctions Enforcement Review and Predictions for 2024
Episode 300 -- Deep Dive into DOJ FCPA Settlement with Two U.K. Reinsurance Companies for Bribery in Ecuador
Episode 296 -- Deep Dive into Clear Channels SEC Settlement of FCPA Violations
Episode 294 -- Catch Up on OFAC Enforcement: 3M and Emigrant Bank
The Maritime Anti-Corruption Network: An In-Depth Conversation
Season 2 - Episode 2 - A Whistleblowers Nightmare: The Uncovering of the 1Malaysia Development Berhad Scandal
The Justice Insiders Podcast: Varsity Blues Reversals Turn DOJ Red
Corruption, Crime, and Compliance - The Ericsson FCPA DPA Breach Settlement
Episode 258 -- Deep Dive into ABB FCPA Settlement
Corruption Crime & Compliance - Deep Dive into the ABB FCPA Case
Life with GDPR - The ABB Enforcement Action from a UK Perspective
The Corruption Files - Episode 15 - The ABB Settlement
The Line Between Gift Giving and Bribery
The Corruption Files - Episode 14 - Walmart with Tom Fox and Michael DeBernardis
Compliance Into The Weeds - Lafarge and the Cost of Moral Bankruptcy
The New Cold War: Risk, Sanctions, Compliance Episode 21: "Interview with Drago Kos of the OECD Working Group on Bribery"
The Justice Insiders: FIFA Corruption Trial – Will the Feds Score Another Goal?
The Presumption of Innocence Podcast: Episode 5 - Doing Business Overseas: The Foreign Corrupt Practices Act
In December 2023, President Biden signed the new Foreign Extortion Prevention Act (FEPA), closing a gap in the Foreign Corrupt Practices Act (FCPA) by criminalizing the “demand side” of foreign bribery. While the FCPA...more
Senator Bob Menendez (D-NJ), former Chair of the U.S. Senate Committee on Foreign Relations, has been found guilty in his federal corruption case for, among other things, bribery, obstruction of justice, and acting as a...more
Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption law and enforcement developments from the past...more
FEPA contains a broad prohibition on corrupt activity and applies to a broad category of public officials. First, FEPA makes it unlawful for any foreign official to “demand, seek, receive, accept, or agree to” receive...more
U.S. companies that do business globally may need to update their compliance training to ensure employees operating in international venues understand new risks. For decades, the Foreign Corrupt Practices Act has made it...more
After years of anticipation, President Biden signed the Foreign Extortion Prevention Act (FEPA) into law on December 22, 2023, ushering in a new era of international anti-corruption prosecution. The FEPA will make it easier...more
On December 22, 2023, President Biden signed the Foreign Extortion Prevention Act (FEPA) into law, revising Section 201 of Title 18 of the U.S. Code concerning bribery of government officials. This significant development...more
On December 22, 2023, President Biden signed into law the Foreign Extortion Prevention Act (FEPA) as part of the fiscal year 2024 National Defense Authorization Act. FEPA criminalizes demand-side bribery by foreign officials...more
Adding to federal prosecutors’ tool kit in fighting global corruption, on December 14, 2023, Congress passed with bipartisan support, the Foreign Extortion Prevention Act (FEPA). As part of the National Defense Authorization...more
INTRODUCTION - On 22 December 2023, President Biden signed into law the National Defense Authorization Act (NDAA), the annual defense spending bill for 2024. Buried hundreds of pages into the NDAA is the new Foreign Extortion...more
On December 14, 2023, with bipartisan support, Congress passed the Foreign Extortion Prevention Act (“FEPA”), making it a federal crime for any foreign government official to demand, receive, or agree to receive a bribe from...more
In California, extortion is a crime. Section 518 of the Penal Code defines "extortion" as "the obtaining of property or other consideration from another, with his or her consent, or the obtaining of an official act of a...more
In 2011, following the adoption of the United Nations Guiding Principles, the OECD Guidelines for Multinational Enterprises (the “Guidelines”)—the only existing intergovernmental guidance to businesses—introduced a new...more
The Financial Crimes Enforcement Network (“FinCEN”) recently issued an advisory urging financial institutions (including certain cryptocurrency businesses) to implement controls to help detect proceeds of foreign public...more
In This Issue. The Financial Crimes Enforcement Network (FinCEN) is urging financial institutions to focus their efforts on detecting the proceeds of foreign public corruption; the Financial Industry Regulatory Authority...more
On January 21, 2022, the Department of Justice (“DOJ”) issued a Foreign Corrupt Practices Act (“FCPA”) Opinion Procedure Release (the “OPR” or “OPR 22-01”) addressing the rarely discussed extortion exception to the FCPA’s...more
Yesterday, I ended my blog post with a few words about what we call in Texas Creative Lawyerin in the context of a Securities and Exchange Commission (SEC) enforcement action where there was zero fine and penalty due to the...more
Corruption can manifest in many different forms, including cronyism, embezzlement, extortion, and bribery, and taints industries and jurisdictions arounds the world on a daily basis. It slows economic growth, thwarts...more
Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption law and case developments from the past month,...more
Yesterday, I posted a short primer on facilitation payments. Today, I want to take up another issue which embroils compliance officers from time to time; that being extortion payments. For compliance officers’ purposes,...more
On Tuesday, former New York State Assembly Speaker Sheldon Silver received a welcomed victory, albeit partial, in the Government’s long running prosecution accusing him of fraud, extortion and money laundering....more
The US Department of Justice (DOJ) is increasingly using the money laundering statute to prosecute individuals in corruption and bribery cases. The Foreign Corrupt Practices Act (FCPA) is the primary statute prohibiting...more
On June 27, the U.S. Supreme Court vacated the conviction of former Virginia Governor Robert McDonnell, narrowing the definition of an “official act” in federal corruption cases. McDonnell v. United States, No. 15-474 (2016)....more