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Compliance Cartels

Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory violations. ... more +
Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory violations.  In response to many corporate scandals evidencing rampant unethical business practices, many nations, including the United States, began passing strict regulatory frameworks aimed at curbing these abuses. Notable pieces of legislation in this area include the U.S. Foreign Corrupt Practices Act (FCPA), Sarbanes-Oxley (SOX), and the U.K. Bribery Act, to name a few. The foregoing statutes and the severe penalties often associated with them form the basis of many modern institutional compliance programs. less -
Guidepost Solutions LLC

Can a Failed Privacy Program Lead to Fentanyl Trafficking or OFAC Violations?

In July 2024, the Federal Bureau of Investigation and Department of Treasury’s Financial Crime Enforcement Network and Office of Foreign Assets Control (OFAC) released a joint notice discussing how Mexican-based Transnational...more

Axinn, Veltrop & Harkrider LLP

Conspiracy Theories Newsletter, 2024 Edition: Eight Predictions for the Future of Cartel Enforcement

2023 was a dramatic year for criminal antitrust enforcement in the United States. The Antitrust Division of the U.S. Department of Justice (“DOJ”) garnered big wins: three convictions at trial,1 $267 million in criminal fines...more

Davies Ward Phillips & Vineberg LLP

Federal Government Enacts Significant Amendments to Canada’s Competition Act

Significant amendments to Canada’s Competition Act (Act) were enacted on June 23, 2022, with the passing of the federal government’s 2022 budget implementation legislation. The amendments foreshadow more aggressive...more

The Volkov Law Group

CCOs and Criminal Cartel Compliance Programs (Part II of III)

The Volkov Law Group on

Chief compliance officers have plenty of things to do and risks to manage.  CCOs have a unique remit and a set of skills that should be applied whenever needed.  While I am not trying to increase CCO workload (and forgive me...more

Hogan Lovells

Bundeskartellamt veröffentlicht neue Leitlinien zu Bußgeldberechnung und Kronzeugenprogramm

Hogan Lovells on

Am 11. Oktober 2021 hat das Bundeskartellamt („BKartA“) zentrale Dokumente für seine Kartellverfolgung aktualisiert und eine Neufassung sowohl seiner Bonusregelung vom 07.03.2006 als auch seiner Bußgeldleitlinien vom...more

The Volkov Law Group

HR and CCOs Watch Out!! — The Antitrust Division Doubles Down on Labor Market Criminal Cartel Activity

The Volkov Law Group on

The Justice Department’s Antitrust Division has targeted collusion in labor markets for criminal prosecution.  This was not unexpected.  Indeed, the Antitrust Division gave plenty of warning to companies that criminal...more

The Volkov Law Group

DOJ Takes Stock of Criminal Cartel Prosecution Program

The Volkov Law Group on

The Justice Department’s Antitrust Division has a long and rich history.  For years, “the Division” as it liked to refer to itself, charted its own path in antitrust enforcement, especially when it comes to criminal...more

The Volkov Law Group

J&F Investmentos Subsidiary, Pilgrim’s Pride, Agrees to $110 its Million Penalty for Antitrust Cartel in Chicken Processing...

The Volkov Law Group on

Shortly before announcing its comprehensive FCPA settlement with DOJ and the SEC, Pilgrim’s Pride agreed with the Justice Department’s Antitrust Division to plead guilty to price-fixing in the chicken processing industry....more

The Volkov Law Group

Bumble Bee CEO Convicted of Participating in Price-Fixing Conspiracy

The Volkov Law Group on

Global companies are paying greater attention to criminal antitrust risks – and with good reason.  We often dwell on the impact to a company of a major FCPA investigation.  A global criminal antitrust investigation often in...more

BCLP

High Court Challenge to the Scope of Company Director Disqualification Undertakings

BCLP on

On 9th December High Court heard one of the first applications to vary Company Director Disqualification Undertakings (“CDU”) given by two directors of a group of companies previously found guilty by the Competition & Markets...more

Hogan Lovells

Algorithms in the spotlight of antitrust authorities

Hogan Lovells on

Joint study by the Bundeskartellamt (German Cartel Office) and the Autorité de la concurrence (French Competition Authority) indicates need for higher compliance standards - Digital ubiquity, and the resulting rules, do not...more

Latham & Watkins LLP

„Lohnt“ sich Kartellrechts-Compliance für Unternehmen?

Latham & Watkins LLP on

USA als Vorreiter und Vorwirkung für Unternehmen in Deutschland - Für das US-Kartellrecht kann diese Frage neuerdings mit einem klaren Ja beantwortet werden. Ein „effektives“ Kartellrechts-Compliance-Programm kann in den...more

Morrison & Foerster LLP

Quarterly Cartel Catch-Up: Recent Developments in Criminal Antitrust for Busy Corporate Counsel - July 2019

Below, we summarize significant cartel enforcement developments from U.S. and other antitrust enforcers in recent months, including the significant change to longstanding policy by the Department of Justice (DOJ) Antitrust...more

Jones Day

Antitrust Alert: New DOJ Criminal Enforcement Policy Boosts Value of Antitrust Compliance Programs

Jones Day on

The U.S. Department of Justice Antitrust Division ("DOJ") recently announced significant revisions to its criminal enforcement policies regarding the value it places on a company's pre-existing antitrust compliance program....more

Cozen O'Connor

DOJ Antitrust Division Now Gives Credit for Compliance Program in Cartel Investigations

Cozen O'Connor on

On July 11, 2019, the U.S. Department of Justice (DOJ), Antitrust Division (Antitrust Division) announced new guidance concerning the effect of compliance programs in criminal antitrust cartel sentencing that significantly...more

McDermott Will & Emery

The Latest: New DOJ Antitrust Division Policy Makes Compliance Programs More Critical than Ever

McDermott Will & Emery on

What Happened: • Last week, the Antitrust Division reported that it has changed its Justice Manual to state that it will consider antitrust compliance at the charging stage in criminal antitrust investigations, instead of...more

The Volkov Law Group

DOJ’s Antitrust Division Announces New Policy for Crediting Corporate Compliance Programs (Part I of II)

The Volkov Law Group on

In yet another major compliance development, the Justice Department announced the adoption of a new policy to credit effective compliance programs in resolving criminal cartel prosecutions against corporations....more

Thomas Fox - Compliance Evangelist

On the Importance of Effective Compliance Programs (and subregulatory guidance)

Compliance Week 2019 is in full swing. The conference opened with a very interesting talk by Principal Deputy Associate Attorney General Claire McCusker Murray. She provided some excellent insights for the compliance...more

The Volkov Law Group

Focusing Antitrust Compliance Programs on the Real Criminal Risks (Part II of II)

The Volkov Law Group on

As chief compliance officers realize the importance of criminal antitrust compliance, it is important to identify the real risk factors. All too often we get lost in the mumbo-jumbo (a technical term, I know) of compliance,...more

The Volkov Law Group

Chief Compliance Officers Have to Address Criminal Antitrust Risks (Part I of II)

The Volkov Law Group on

We often read articles and blog postings about anti-corruption, anti-money laundering, export controls and sanctions compliance issues. The focus on these topics is justified. However, there is one glaring omission –...more

Morgan Lewis

2017 Mid-Year Global Cartel Enforcement Report

Morgan Lewis on

Fines significantly down, several enforcement firsts and a strong pipeline of new, mainly domestic cartel cases around the world....more

The Volkov Law Group

Parallel Universes: Antitrust Leniency and the FCPA Pilot Program

The Volkov Law Group on

The world of science fiction can be exhilarating. If you ever read The Foundation Trilogy or Martian Chronicles, you know what I mean. The concept of parallel universes has always been an intriguing idea where believers can...more

Sheppard Mullin Richter & Hampton LLP

EU Legal Developments That May Impact Your Business in 2017

Sheppard Mullin’s EU team has created a list of major legal shifts that await General Counsel and Compliance Officers in the areas of competition, EU regulatory and trade in 2017. These challenges may have an impact on your...more

Morgan Lewis

2016 Mid-Year Global Cartel Enforcement Report

Morgan Lewis on

Cartel enforcement activity promises to remain busy In the coming months and into 2017 Cartel enforcement remains a priority for competition authorities around the world. Global cartel fines totaled more than $6...more

The Volkov Law Group

The Antitrust Leniency Model and FCPA Enforcement

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I am always wary of simplistic policy proposals – often the simple idea to apply one policy to another subject matter, just does not work. Instead, policy debate will turn to the simple idea and how it can easily be applied...more

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