Bribery The Foreign Corrupt Practices Act

News & Analysis as of

Anti-bribery compliance in India: Both sword and shield

In recent years, both the United States Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) have stepped up their enforcement of the Foreign Corrupt Practices Act (FCPA), including to address...more

Anti-Corruption Enforcement Has Gone International

Matt Stephenson, myself and others have engaged in a dialogue about where Foreign Corrupt Practices Act (FCPA) enforcement may be headed under the incoming administration. I have tried to focus on why compliance with...more

Coordinating Third Party Due Diligence and Procurement

Third party risk management is easily one of the most challenging risks for compliance officers. With all the attention and hype surrounding third party risk, companies have marshaled attention and resources to mitigate the...more

Aggressive Remediation: Embraer and JP Morgan

There is no question that the Justice Department has raised compliance program expectations in a number of areas. Whatever you may think about the efficacy or fairness of the FCPA Pilot Program, the Justice Department has...more

White Collar Crime Law Enforcement in a Trump Justice Department - 8 Predictions

After a conventional presidential campaign, determining the policy priorities and direction of the incoming administration with respect to the Justice Department’s white collar law enforcement responsibilities can be a...more

Don’t Let Forced Labor and Bribery in Your Supply Chain Spoil the Holidays

The holiday retail season is an ideal time to check that forced labor and bribery—two top and interconnected supply-chain threats—do not undermine the success of your critical sales period. Not long ago, many in the...more

New French Anti-Corruption Law: Companies Doing Business in France Must Beware

On November 8, 2016, France modernized its anti-corruption enforcement regime and adopted the Law on Transparency, the Fight against Corruption and Modernization of Economic Life (known in France as “Sapin II,” named after...more

Why FCPA Compliance Makes America Great

Last week, a colleague asked me what I thought the Trump administration might hold for Foreign Corrupt Practices Act (FCPA) enforcement specifically and for the greater compliance discipline in general. I have been exploring...more

FCPA and Jail - Are Corporate Officers Really at Risk?

On Oct. 31, James McClung, a former Louis Berger International Inc. executive, self-surrendered to the Bureau of Prisons to begin his year-and-a-day sentence for violations of the Foreign Corrupt Practices Act (FCPA)....more

A Cautionary Illustration of the Need for Accounting and Compliance Reviews

Embraer SA, Brazil's flagship aerospace manufacturer and a worldwide competitor across various aviation markets, experienced first-hand the scope and reach of the Foreign Corrupt Practices Act (FCPA). Embraer agreed to pay...more

FCPA Enforcement Going Forward in the Trump Administration

Donald Trump has gone on the record as saying the Foreign Corrupt Practices Act (FCPA) is a “horrible law and it should be changed” and that it puts US businesses at a “huge disadvantage.” This statement was made in the...more

Hunter S. Thompson and the World of International Corruption

In a tale worthy of the famous Hunter S. Thompson maxim, that “When the going gets weird, the weird turn pro”; the tale of BSG Resources (BSGR) and the Simandou mining concession in Guinea took a very weird turn this week...more

When Leslie Caldwell Talks FCPA, You Should Listen

November begins the final push for the compliance conference season, which customarily ends with the ACI National FCPA Conference. During November and into early December, Department of Justice (DOJ) officials have...more

AAG Caldwell Touts Success of FCPA Enforcement and Pilot Program

In a speech last week, Criminal Division Assistant Attorney General Leslie Caldwell touted the success of the FCPA Pilot Program. AAG Caldwell outlined the success of the FCPA enforcement program, listing many of the...more

ISO 37001: Why Your Anti-Corruption Policy Needs to Go Global

Ten years ago the standard anticorruption policy was nearly exclusively FCPA-focused. DOJ and SEC enforcement actions were the primary, if not the only, concern for corporate executives and board members. The UK Bribery Act...more

When Lawyers Cross the Line – Breaking Bad Under the Law

While reading the Embraer settlement documents, I read over the facts implicating a senior legal executive and his/her involvement in the Embraer bribery scheme. Truthfully, I had a slight gasp as I read about a fellow lawyer...more

Lessons Learned from Embraer $205 Million FCPA Settlement (Part II of II)

The Embraer FCPA settlement action contains a number of important lessons learned and compliance reminders. In several significant respects, the Embraer case confirms in several areas why proactive compliance programs are...more

Embraer Finally Lands $205 Million FCPA Settlement (Part I of II)

After years of investigation, disclosures, and press reports, the Embraer FCPA case finally came to a close. Hopefully, we will not see more of these long-term, seemingly endless investigations. The Justice Department and the...more

FCPA Enforcement Action Highlights Risks for the Financial Services Industry and Individual Executives

New York-based hedge fund Och-Ziff Capital Management Group (the “Hedge Fund”) agreed to pay approximately $412 million to resolve charges brought by the U.S. Securities and Exchange Commission (“SEC”) and Department of...more

Embraer FCPA Enforcement Action – Part IV

I conclude my exploration of the recently announced Department of Justice (DOJ) and Securities and Exchange Commission (SEC) Foreign Corrupt Practices Act (FCPA) enforcement action with the announcement of the resolution of...more

Embraer FCPA Enforcement Action – Part III

Today I continue my exploration of the recently announced Department of Justice (DOJ) and Securities and Exchange Commission (SEC) Foreign Corrupt Practices Act (FCPA) enforcement action with the announcement of the...more

Embraer Settles FCPA Charges with DOJ, SEC

“Two out of three ain’t bad” was the refrain of a well known song by rock star Meatloaf some years back. While Meatloaf probably was not thinking about government investigations, sometimes the notion applies as aircraft...more

Embraer FCPA Enforcement Action – Part II

Today I continue my exploration of the recently announced Department of Justice (DOJ) and Securities and Exchange Commission (SEC) Foreign Corrupt Practices Act (FCPA) enforcement action with the announcement of the...more

Embraer FCPA Enforcement Action, Part I

The Department of Justice (DOJ) and Securities and Exchange Commission (SEC) continued their stunning 2016 run of Foreign Corrupt Practices Act (FCPA) decisions with the announcement of the resolution of the Embraer SA...more

This Week in FCPA-Episode 27, the Walla Walla Edition [Video]

Show Notes for Episode 27, week ending October 21, 2016-the Walla Walla Edition 1. Lennox Industries self-reports a $425 bribe; 2. Another guilty plea in FIFA corruption scanda; 3. Public Citizen letter to DOJ/SEC re:...more

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