News & Analysis as of

Bribery Recordkeeping Requirements

Adams and Reese LLP

Beyond Borders: Navigating Global Business Compliance with the FCPA

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On March 7th, the Department of Justice (DOJ) announced a new whistleblower reward program intended to help prosecutors bring more foreign corruption cases. Under the new program, individuals who report corporate misconduct...more

Guidepost Solutions LLC

Emerging Expectations from the Latest Enforcement Actions Over Off-Channel Communications

Since December 2021, the U.S. Securities and Exchange Commission (SEC) and Commodity Futures Trading Commission (CFTC) have levied almost $3.0 billion in penalties for longstanding failures by 39 broker-dealers, swap dealers,...more

Davis Wright Tremaine LLP

Broker Dealer Regulatory Digest - August 2023

The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency, specifically focusing on:...more

Guidepost Solutions LLC

Mergers + Acquisitions: 5 Tips For Navigating FCPA Risks

Among the risks inherent in a merger or an acquisition, few bring the financial and reputational consequences of the U.S. Foreign Corrupt Practices Act (“FCPA”). Background - The FCPA prohibits the offer, promise,...more

Pillsbury - Global Trade & Sanctions Law

Heightened Risks and Plenty of Pitfalls: Avoiding Corruption during COVID-19

Over the past nine months, companies and governments have competed goods and materials amidst scarcity and disrupted supply chains.  At the same time, governments, central banks, international organizations and NGOs have...more

Thomas Fox - Compliance Evangelist

The Problems with Facilitation Payments

The original version of the FCPA, enacted in 1977, contained an exception for payments made to non-U.S. officials who performed duties that were “essentially ministerial or clerical”. In 1988 Congress responded by amending...more

Locke Lord LLP

The Foreign Corrupt Practices Act

Locke Lord LLP on

FCPA AT A GLANCE - The Foreign Corrupt Practices Act of 1977 (the “FCPA”) was enacted in the wake of Securities & Exchange Commission (“SEC”) investigations in the mid-1970’s during which hundreds of U.S. companies...more

Sheppard Mullin Richter & Hampton LLP

Ninth Circuit Holds That Statutes Do Not Constitute “Rules or Regulations of the SEC” for Purposes of Sarbanes-Oxley Act...

In Wadler v. Bio-Rad Laboratories, Inc., No. 17-16193, 2019 WL 924827 (9th Cir. Feb. 26, 2019), the United States Court of Appeals for the Ninth Circuit held that statutes, including the Foreign Corrupt Practices Act...more

Dechert LLP

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

Dechert LLP on

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

Manatt, Phelps & Phillips, LLP

Health Update - September 2015

Latest Healthcare False Claims Act Roundup and Top 3 Best Practices to Reduce Exposure - As the legal landscape in healthcare becomes increasingly complex, healthcare companies that receive federal program funds face...more

Winthrop & Weinstine, P.A.

Minnesota Political Law Guidelines Updated

Table of Contents: Lobbyist Registration; Lobbyist Report and Record Keeping; Corporate Political Activity; Gifts To Public Officials Prohibited; Issues In Communicating With Public Officials; Employment Law Issues;...more

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