News & Analysis as of

Bribery Foreign Corrupt Practices Act (FCPA) Cooperation

BakerHostetler

The Lines Are Open! DOJ Adds New Tool in Anticorruption Efforts With Whistleblower Pilot Program

BakerHostetler on

Building on the recent passage of the Foreign Extortion Prevention Act (FEPA), at the American Bar Association’s 2024 National Institute on White Collar Crime conference in San Francisco earlier this month (2024 ABA...more

American Conference Institute (ACI)

The Foreign Extortion Prevention Act: Much Ado About Nothing?

In December 2023, President Joe Biden signed the Foreign Extortion Prevention Act (FEPA) into law under the broader Fiscal Year 2024 National Defense Authorization Act (NDAA). While FEPA’s sponsors hailed it as “the most...more

Thomas Fox - Compliance Evangelist

Self-Disclosure is Now the Key

The Department of Justice (DOJ) has been making significant strides in emphasizing the importance of voluntary self-disclosure in corporate enforcement cases, particularly in the realm of the Foreign Corrupt Practices Act...more

Thomas Fox - Compliance Evangelist

The SAP FCPA Enforcement Action-Part 4: The Fines: Self-Disclose, Self-Disclose, Self-Disclose

We continue our exploration of the SAP Foreign Corrupt Practices Act (FCPA) enforcement action. Today we go full geek in a look at the fine and penalty and most importantly what the fine and penalty communicate about what the...more

Barnea Jaffa Lande & Co.

Cooperating May Credit Corporations with Leniency in Enforcement

Last September, US Deputy Attorney General Lisa Monaco issued a memorandum instructing the various departments in the Department of Justice to adopt a lenient enforcement policy toward corporations. The aim of this policy is...more

WilmerHale

Global Anti-Bribery Year-in-Review: 2022 Developments and Predictions for 2023

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While Foreign Corrupt Practices Act (FCPA) enforcement activity has not come close to returning to the heights seen a few years ago, 2022 reflected significant increases from the prior year in both the number of cases against...more

Latham & Watkins LLP

DOJ’s Updated Corporate Enforcement Policy Aims to Incentivize Compliance

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Companies that self-disclose, cooperate, and remediate could benefit from significantly reduced fines and possible declinations even in cases with aggravating factors. In a speech at Georgetown University Law Center on...more

Dorsey & Whitney LLP

DOJ Announces Additional Incentives for Corporate Cooperation in Criminal Enforcement

Dorsey & Whitney LLP on

On January 17, 2023, Assistant Attorney General for the United States Department of Justice Kenneth A. Polite Jr. announced significant revisions to the Criminal Division’s Corporate Enforcement Policy (“CEP”). Four months...more

WilmerHale

2021 Global Anti-Bribery Year-in-Review

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In 2021, the number of publicly resolved Foreign Corrupt Practices Act (FCPA) cases was relatively low compared with previous years, but there were numerous interesting developments, and enforcement activity going forward...more

K&L Gates LLP

Voluntary Disclosure - Special Edition - A Debrief on the 37th International Conference on the Foreign Corrupt Practices Act

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White collar practitioners Neil Smith, William Semins, Nicole Stockey, and David Peet discuss their key takeaways from this year’s 37th International Conference on the Foreign Corrupt Practices Act....more

WilmerHale

Airbus to Pay Record $4 Billion to Settle Global Bribery Scheme

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On January 31, 2020, the Department of Justice (“DOJ”) agreed to resolve allegations that Airbus SE (“Airbus”), a France-based aerospace company, used third-party business partners to bribe government officials and airline...more

WilmerHale

$1 Billion Ericsson Resolution, Three Jury Verdicts Cap Off Busy Fourth Quarter for US FCPA Enforcement

WilmerHale on

On December 6, 2019, the Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) agreed to resolve allegations that multinational telecommunications company Telefonaktiebolaget LM Ericsson (Ericsson or...more

K&L Gates LLP

Are We Living in the Golden Age of Cooperation or Not? The Implications of SEC Chair Jay Clayton’s Recent Comments Challenging...

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In a speech to the Economic Club of New York on September 9, Securities and Exchange Commission (“SEC”) Chair Jay Clayton lamented foreign regulators’ inconsistent enforcement of their own anti-corruption laws that impose...more

Butler Snow LLP

2019 Developments and Trends in the Foreign Corrupt Practices Act (FCPA) & Global Anti-Corruption Efforts, Part 2 of 3

Butler Snow LLP on

Previously, we introduced you to this topic and provided updates about the positive international trends in anti-corruption efforts, bribery, and the Organization for Economic Cooperation and Development (OECD). Today, we...more

WilmerHale

Foreign Corrupt Practices Act Alert: Global Anti-Bribery Year-in-Review: 2018 Developments and Predictions for 2019

WilmerHale on

Despite predictions of a slow-down in enforcement under the Trump administration—and indications that enforcement in some areas has decreased in the past year1—2018 was yet again an active year for FCPA enforcement. The year...more

BCLP

Anti-Corruption Enforcement Webinar: 2018 in Review

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Anti-Corruption enforcement remained a top priority in France, the UK, and the US in 2018. Join our firm's Global Anti-Corruption Team as they explain and analyze these three countries' anti-corruption enforcement efforts and...more

WilmerHale

Lessons From Across the Ocean: SFO Director’s Speech in Washington Provides Insight Into the Future of UK Investigations

WilmerHale on

On 28 November 2018, Lisa Osofsky, Head of the UK Serious Fraud Office (“SFO”), delivered the keynote address at the 35th International Conference on the Foreign Corrupt Practices Act (“FCPA”) in Washington DC. After a...more

Holland & Knight LLP

Petrobras Agrees to Pay More Than $1.8 Billion for Facilitating FCPA Violations

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• Four years ago, Brazilian authorities began Operation Car Wash, a wide-ranging and still ongoing corruption and money laundering investigation that has spanned 11 countries. • The fallout continues with a recent U.S....more

The Volkov Law Group

DOJ Issues Declination and Disgorgement Under FCPA Corporate Enforcement Policy

The Volkov Law Group on

In a recently released letter, the Justice Department issued a declination to the Insurance Corporation of Barbados Limited (ICBL) for violations of the FCPA under the FCPA Corporate Enforcement Policy. DOJ required ICBL to...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - July 2018

ANTICORRUPTION DEVELOPMENTS - DOJ Extends FCPA Corporate Enforcement Policy to Misconduct in Mergers and Acquisitions - On July 25, 2018, in a speech to the Ninth Global Forum on Anti-Corruption Compliance in High Risk...more

Saul Ewing LLP

Happy Birthday FCPA: Implications of DOJ’s New FCPA Corporate Enforcement Policy on the Act’s 40th Anniversary

Saul Ewing LLP on

Today being the fortieth anniversary of the December 19, 1977 enactment of the Foreign Corrupt Practices Act (“FCPA”), we offer this Client Alert in celebration of the occasion. Fittingly, the U.S. Department of Justice...more

Holland & Knight LLP

DOJ Makes Permanent Its Program to Incentivize Self-Disclosure in FCPA Investigations

Holland & Knight LLP on

• The U.S. Department of Justice's (DOJ) pilot program established in 2016 to incentivize companies to self-report violations of the Foreign Corrupt Practices Act (FCPA) will, with slight revisions, be made permanent. •...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - Russian

ANTICORRUPTION DEVELOPMENTS – Former Magyar Telekom Executives Settle Bribery Charges – On April 24, 2017, the Securities and Exchange Commission (SEC) announced that two former executives of Magyar Telekom, a...more

Ruder Ware

Sally Yates’ was Already Famous for Changing the Focus of Compliance Investigations - The Yates Memorandum

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By now the whole world knows about Sally Yates. We are likely to see a lot more of her as a central figure in Congressional investigations. For some of us who deal with compliance investigations, Sally Yates was famous long...more

Bass, Berry & Sims PLC

FCPA: 2016 Year in Review & 2017 Enforcement Predictions

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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

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