News & Analysis as of

China Compliance Dept. of Justice

Red Notice Newsletter - Chinese

Anticorruption Developments - Former Magyar Telekom Executives Reconcile Bribery Charges - April 24, 2017, the US Securities and Exchange Commission (SEC) announced that the Hungarian telecommunications company...more

Top Ten International Anti-Corruption Developments for March 2017

by Morrison & Foerster LLP on

In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international anti-corruption developments from the past month, with links to primary...more

My China Compliance Diary

When my supervision (probation) ended in January 2017, the US District Court in DC released my passport, and I could once again travel internationally. And with that milestone, a note of thanks to all the international event...more

Top Ten International Anti-Corruption Developments for January 2017

by Morrison & Foerster LLP on

In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international anti-corruption developments from the past month, with links to primary...more

Dentons' pick of global regulatory trends to watch in 2017 - Anti-corruption

by Dentons on

Focus on the US - Anti-corruption enforcement in the United States has changed dramatically in the past year and its future remains unclear. What direction will Attorney General Jeff Sessions take the US Department of...more

U.S. Customs and the New Trump Administration: Your Top Ten Questions Answered

by Foley & Lardner LLP on

During the campaign, U.S. Customs & Border Protection (CBP) was mostly mentioned by President Trump in the context of illegal immigration. Controlling the flow of people, however, is only one of the jobs of CBP, which is part...more

General Cable FCPA Enforcement Action – Part I: The Bribery Schemes

by Thomas Fox on

The Department of Justice (DOJ) and Securities and Exchange Commission (SEC) continued their stunning run of 2016 Foreign Corrupt Practices Act (FCPA) enforcement actions right up to the end of the year with the announcement...more

Top Ten International Anti-Corruption Developments for November 2016

by Morrison & Foerster LLP on

In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international anti-corruption developments from the past month, with links to primary...more

JPMorgan Sons and Daughters FCPA Enforcement Action, Part III-St. Mark’s Revealed

by Thomas Fox on

This week I am exploring the JP Morgan Chase (JPM) and its subsidiary, JPMorgan Securities (Asia Pacific) Limited (JPM-APAC), (collectively ‘the company’) Foreign Corrupt Practices Act (FCPA) enforcement action which...more

Lessons Learned From FCPA Enforcement Against JP Morgan for Sons and Daughters Referral Program

by Michael Volkov on

Last week, the Justice Department and the SEC finally brought to a close the Sons and Daughters or Princelings investigation. Pending investigations against four other companies still remain to be resolved....more

JPMorgan Sons and Daughters FCPA Enforcement Action, Part II

by Thomas Fox on

Today I will consider the superior result achieved by JPM in its FCPA resolution. Not only did it receive a 25% discount off the bottom of the US Sentencing Guidelines fine range but it received a NPA and not even a Deferred...more

JPMorgan Sons and Daughters FCPA Enforcement Action: Part I – Venice and Fog

by Thomas Fox on

JP Morgan Chase (JPM) and its subsidiary, JPMorgan Securities (Asia Pacific) Limited (JPM-APAC) resolved its Foreign Corrupt Practices Act (FCPA) matter last week, obtaining a Non-Prosecution Agreement (NPA) from the...more

Top Ten International Anti-Corruption Developments for October 2016

by Morrison & Foerster LLP on

In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international anti-corruption developments from the past month, with links to primary...more

Landmark SEC Decision Cites Compliance, Diligence in Decision Not to Prosecute FCPA Violations

by NAVEX Global on

In a remarkable affirmation of the value of robust compliance and due-diligence programs, the Securities and Exchange Commission last month announced that it would not prosecute a U.S. company for potential violations of the...more

GSK Settles SEC FCPA Case for $20 Million

by Michael Volkov on

The SEC finished with the last nail in GSK China’s coffin by announcing a $20 FCPA million settlement for GSK’s violations in China. The Justice Department declined to prosecute this case. In 2014, a Chinese court...more

Double Play, Double Declinations: DOJ Pushes FCPA Pilot Program Benefits

by Michael Volkov on

DOJ’s FCPA Pilot Program was panned when it was announced in April 2016. Critics contended that the incentive for voluntary disclosure of FCPA violations to DOJ was inadequate....more

The Oscar Meyer Wiener Theme and Revisiting GSK in China

by Thomas Fox on

Last week a true American original died when Richard Trentlage passed away. If you do not know his name you certainly know signature contribution to American culture, the Oscar Meyer Weiner Song. Rather amazingly Trentlage...more

Key Takeaways: Government Enforcement Investigations – Trends and Perspectives from the UK, US and China

On September 20, 2016, Skadden presented a seminar titled “Government Enforcement Investigations – Trends and Perspectives from the UK, US and China” in London. The UK Financial Conduct Authority (FCA) Director of Enforcement...more

Declinations and Profits Disgorgement – It Was There All Along

by Thomas Fox on

Last week there were two declinations issued by Department of Justice (DOJ) for Foreign Corrupt Practices Act (FCPA) matters. The matters involved two Texas based, privately held companies. The first was HMT LLC (HMT) which...more

Top Ten International Anti-Corruption Developments for July 2016

by Morrison & Foerster LLP on

In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international anti-corruption developments from the past month, with links to primary...more

Headlines from Mid-Year FCPA Enforcement Review

by Michael Volkov on

Just to add my voice to the cottage industry surrounding FCPA enforcement and compliance, I wanted to take a deep breath and offer some observations on FCPA enforcement in 2016. There are a few significant headlines...more

Three Key Questions to Ask in Hiring of Family Members of Foreign Officials

by Thomas Fox on

One of the top academic commentators in the anti-corruption space is Matthew C. Stephenson, co-founder of the Global Anticorruption Blog. I was intrigued by Stephenson’s piece, entitled “Does an FCPA Violation Require a Quid...more

Froome Ends Tour With Win; JP Morgan to End Sons and Daughters Case?

by Thomas Fox on

I begin today’s post with a tip of the (cycling) helmet to Englishman Chris Froome who yesterday won his third Tour de France championship. Froome overcame a great many obstacles, not the least of which was being involved a...more

Enforcement Week III: Johnson Controls FCPA Enforcement Action – Part 2

by Thomas Fox on

I continue my review of the Johnson Controls, Inc. (JCI) Foreign Corrupt Practices Act (FCPA) enforcement action today by focusing on the Department of Justice’s (DOJ’s) Declination to Prosecute. Yesterday, I considered the...more

Johnson Controls Pays $14 Million for China FCPA Violations: DOJ Declines Prosecution

by Michael Volkov on

At first glance, the SEC’s recent enforcement action against Johnson Controls for $14 million for FCPA violations in China, along with a Justice Department declination under its new Pilot Program, appears to be a “routine”...more

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