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Bribery Third-Party Agents

Thomas Fox - Compliance Evangelist

Albemarle FCPA Enforcement Action: Part 2 – How to Hire Corrupt Agents

Last week, Albemarle Corporation (Albemarle), agreed to pay more than $218 million to resolve investigations by the U.S. Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) into violations of the...more

Thomas Fox - Compliance Evangelist

The Ahsanis’ Information – The Corruption Schemes

This week I am mining the guilty pleas of the former Unaoil Chief Executive Officer (CEO), Cyrus Ahsani, and former Chief Operations Officer (COO), Saman Ahsani, for what they might mean for Foreign Corrupt Practices Act...more

Thomas Fox - Compliance Evangelist

Corruption in China: Part 1 – I am Shocked, Just Shocked

Sometimes you have to wonder if companies ever have figured out that they need to comply with the Foreign Corrupt Practices Act (FCPA) by putting in place a compliance program that actually works. ...more

The Volkov Law Group

CCO and CLO “Authority”: A Fundamental Requirement

The Volkov Law Group on

A basic compliance program control, which is often overlooked (or assumed to exist), is the requirement that a chief compliance officer and/or chief legal officer have the authority to stop a specific contract or business...more

The Volkov Law Group

Vantage Drilling Forks Over $5 Million for SEC FCPA Settlement

The Volkov Law Group on

The SEC announced last week a $5 million FCPA settlement with Vantage Drilling International (“Vantage”), a Texas-based offshore drilling company. ...more

Thomas Fox - Compliance Evangelist

Michael Cohen, 3rd Party Consultants and Hunter S. Thompson: Part III – Where is Uncle Duke?

We continue our Hunter S. Thompson themed week in honor of Michael Cohen and his Essential Consulting LLC entity. Today we honor Thompson’s alter ego Uncle Duke. For those who might not know just who Uncle Duke might be, you...more

Thomas Fox - Compliance Evangelist

Michael Cohen, 3rd Party Consultants and Hunter S. Thompson: Part II, Full Gonzo

We continue our Hunter S. Thompson themed week in honor of Michael Cohen and his Essential Consulting LLC entity and his work which he sardonically named “Project Sunlight”. There may not be a finer example of full Gonzo...more

Thomas Fox - Compliance Evangelist

Michael Cohen, 3rd Party Consultants and Hunter S. Thompson: Part I

I hope you were able to check out the first ever Compliance Into The Weeds emergency podcast, where Matt Kelly and myself took a look at some of the initial information which came out about the payments to the president’s...more

The Volkov Law Group

Mondelez FCPA Enforcement Action — An Abuse of Prosecutorial Discretion?

The Volkov Law Group on

The first FCPA enforcement action for 2017 landed with very little fanfare. The SEC reached a settlement with Mondelez International for $13 million. The facts surround the hiring of an agent in India and the failure of...more

Thomas Fox - Compliance Evangelist

General Cable FCPA Enforcement Action – Part III: The Denouement

This week I have been exploring the General Cable Corporation (General Cable) Foreign Corrupt Practices Act (FCPA) enforcement action. It was settled with the Department of Justice (DOJ) via a Non-Prosecution Agreement (NPA)...more

Thomas Fox - Compliance Evangelist

From Altamont to Airbus

What was one of the most tragic events in the history of rock and roll? High up on the list must rank the Altamont concert, held at Altamont Race Track on December 6, 1969. It was so bad that many people felt the 60s actually...more

Thomas Fox - Compliance Evangelist

Doing Business in Cuba Under the FCPA – Part II

Today, I continue my exploration of doing business in Cuba from the Foreign Corrupt Practices Act (FCPA) perspective. Yesterday, I made clear that anyone you do business with in Cuba is going to be a foreign official under...more

The Volkov Law Group

Bribery Requires – Money

The Volkov Law Group on

I have to confess – I love the show Shark Tank. Mr. Wonderful, Kevin O’Leary, is my favorite Shark. Mr. Wonderful often reminds the contestants and other Sharks that the central issue in considering business proposals is –...more

Proskauer - Corporate Defense and Disputes

Louis Berger International Pays $17 Million Penalty for FCPA Violation

On July 17, 2015, Louis Berger International, Inc., a New Jersey-based construction management company, entered into a deferred prosecution agreement (DPA) with the Department of Justice under which it agreed to pay a $17.1...more

Thomas Fox - Compliance Evangelist

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

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

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