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Risk Assessments-the Cornerstone of Your Compliance Program, Part I

One cannot really say enough about risk assessments in the context of anti-corruption programs. Since at least 1999, in the Metcalf & Eddy enforcement action, the US Department of Justice (DOJ) has said that risk assessments...more

Nixon Announces Resignation; GSK Just Resigns

Next week, Shanghai’s No. 1 Intermediate People’s Court is scheduled to open a trial against Peter William Humphrey, a 58-year-old British national, and his wife, Yu Yingzeng, a 61-year-old American, on charges of illegally...more

Smith & Wesson Pays $2 Million to Resolve SEC Charges

On July 28, Smith & Wesson Holding Corporation, one of the largest gun manufacturers in the United States, agreed to pay more than $2 million to settle Securities and Exchange Commission charges alleging that it had bribed...more

Red Notice Newsletter - July 2014

Welcome to the July 2014 edition of Red Notice, a publication of Akin Gump Strauss Hauer & Feld LLP. This month on the anticorruption front, two Noble Corporation executives settle with the U.S. Securities and Exchange...more

DOJ, SEC Announce More Charges In Broker-Dealer Foreign Bribery Case

On April 14, the DOJ and the SEC announced additional charges in a previously announced case against employees of a U.S. broker-dealer related to an alleged “massive international bribery scheme.” ...more

The SEC’s Enforcement Of An Elastic “Internal Controls” Requirement

The SEC knows that it has broad enforcement authority. In the FCPA arena, the SEC has civil authority over bribes, but more importantly, enforcement authority over books and records and internal controls. It is this latter...more

The Sussex Vampyre And The ADM FCPA Settlement

Today I want to use the story of The Sussex Vampyre as the starting point for an inquiry into the recent Archer-Daniels-Midland Corp (ADM) Foreign Corrupt Practices Act (FCPA) enforcement action. In the story, Holmes receives...more

The So-Called Re-Emergence Of Gifts, Meals And Entertainment As A Compliance Problem

Forgive me for taking the FCPA Paparazzi to task but when they deserve it, they deserve it. A quick diversion — I often am asked by fellow bar members and commenters if I am referring to them as being a member of the...more

Alcoa Subsidiary Pleads Guilty to FCPA Charge, Will Pay $348 Million

On January 9, Alcoa World Alumina LLC, a majority-owned and controlled global alumina sales company of Alcoa Inc., agreed to plead guilty and to pay $223 million in criminal fines and forfeitures to resolve charges that it...more

We Mean What We Say – FCPA Enforcement Begins The Year With A Bang

Gone are the days when everyone wondered whether FCPA enforcement was slowing down. The Justice Department and the SEC have answered that question with a resounding statement – “We are here to stay.”...more

SEC Enforcement Year in Review - 2013

Marked by leadership changes, high-profile trials, and shifting priorities, 2013 was a turning point for the Enforcement Division of the Securities and Exchange Commission (the “SEC” or the “Commission”). While the results of...more

January 2014 FCPA Digest

In this issue: - Recent Trends and Patterns in FCPA Enforcement - Foreign Bribery Criminal Prosecution under the FCPA - Foreign Bribery Civil Actions Instituted by the Department of Justice under the...more

The 2013 FCPA Year In Review - Corporate Enforcement Actions

In my final post of 2013, I reviewed all of the individual Foreign Corrupt Practices Act enforcement actions which occurred in the past year. In this first post of 2014, I review all the corporate enforcement actions in 2013....more

Supermarket To The World – The ADM FCPA Enforcement Action

Last week, it was announced by the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) that it had settled an enforcement action with Archer-Daniels-Midland Company (ADM). The DOJ resolved a criminal...more

The FCPA Person Of The Year – The Prosecutor

To continue a “tradition” on Corruption Crime and Compliance, I like to end the year with recognition of the “person of the year,” referring to the institution which has had the most impact in the enforcement and compliance...more

FCPA Compliance and Ethics Report-Episode 31-the FCPA Year in Review, Corporate Enforcement Actions [Video]

In this episode, I review the corporate FCPA enforcement actions of 2013. ...more

FCPA Compliance and Ethics Report-Episode 30-Interview with the FCPA Professor-Part 2 [Video]

This episode 30 is Part 2 of my interview with the FCPA Professor. ...more

Red Notice Newsletter - December 2013

Introduction - Welcome to the December 2013 edition of Red Notice, a publication of Akin Gump Strauss Hauer & Feld LLP. This month on the anticorruption front, an oil services giant agrees to pay over a quarter...more

How Straight From The Lion’s Mouth Informs Your Hotline

The symbol of Venice is the Lion of St. Mark. The use of this symbol led to the maxim ‘straight from the lion’s mouth’. This adage came about because the Republic of Venice had its own hotline system where citizens could...more

New Risks Associated with Simultaneous U.S. FCPA and U.K. Bribery Act investigations

On November 20, 2013, during a panel presentation at the 30th International Conference on the Foreign Corrupt Practices Act (“FCPA”), current and former prosecutors from the United States and the United Kingdom discussed the...more

The FCPA May Have its Flaws, but it is Not Anti-Business

“The U.S. government is too restrictive in trying to prevent its companies from corruption abroad and that’s hurting business expansion in Asia and elsewhere, according to Penn National Gaming Chairman Peter...more

Tryin’ to Make a Dollar out of Fifteen Cents: The Diebold FCPA Settlement Explains What Officials Did on Their Vacation

Vacation is great, but it can involve a great deal of planning. And, paradoxically, leisure travel can involve more planning than traveling for business. That travel-related work stands out as a centerpiece of the October...more

SEC Administrative Action Resolves Foreign Bribery Allegations

On October 24, the SEC released a cease-and-desist order that resolves FCPA allegations against a Michigan-based medical technology company. The SEC alleged that the company’s subsidiaries in five different...more

DOJ, SEC Announce FCPA Actions Against U.S. ATM Maker

On October 22, the DOJ and the SEC announced parallel criminal and civil actions against a U.S. company for allegedly violating the FCPA by paying bribes and falsifying documents in connection with selling ATMs to bank...more

Commercial Bribery on the Table in Diebold FCPA Actions

Last week the SEC and Justice Department brought parallel FCPA enforcement actions charging Ohio-based Diebold, Inc., a global provider of ATMs and bank security systems. From the SEC’s press release: “[S]ubsidiaries...more

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