Corruption The Foreign Corrupt Practices Act

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LRN Compliance Program Effectiveness Report: Part III

This week I have been considering the LRN Corporation’s 2016 Ethics and Compliance Program Effectiveness Report (LRN Report) by outlining some of its general findings. Today, I want to conclude by using the Report as a road...more

LRN Compliance Program Effectiveness Report: Part II

Yesterday I began a series on the LRN Corporation’s (LRN) 2016 Ethics and Compliance Program Effectiveness Report (Report) by outlining some of its general findings. Today, I want to focus on its detailed findings as it...more

Understanding the New DOJ Guidance: Part 1 – Tone at the Top

In February, the Department of Justice’s Fraud Section offered a new perspective on what the government expects in a compliance program in the form of a series of questions that companies should be prepared to answer about...more

Justice Department Reveals How It Evaluates Corporate Compliance Programs

The U.S. Department of Justice (DOJ) Fraud Section recently published its "Evaluation of Corporate Compliance Programs" that lists 1) the topics it explores and 2) the questions it asks when it assesses the effectiveness of a...more

Rules of the (International) Road

Going international is a complicated undertaking. Your specific situation and concerns will determine the steps required. The following outlines, very generally, some issues you must consider as you contemplate international...more

LRN Compliance Program Effectiveness Report: Part I (and Farewell to Chuck Berry)

Last week I interviewed Susan Divers, Senior Advisor at LRN Corporation, on the company’s 2016 Ethics and Compliance Program Effectiveness Report (Report). The Report was a fascinating review of the evolution of compliance...more

FCPA Pilot Program Motors On

No one was really surprised when Kenneth Blanco, Acting Assistant Attorney General for the Criminal Division, US Department of Justice, announced last week that DOJ was planning to continue the FCPA Pilot Program past April...more

FCPA: 2016 Year in Review & 2017 Enforcement Predictions

Bass, Berry & Sims announces the release of its "FCPA: 2016 Year in Review & 2017 Enforcement Predictions," a review of trends and developments in FCPA as well as a look ahead into what to expect for 2017. The newly released...more

FCPA Compliance Report-Episode 313-Adam Davidson on Donald Trump's Worst Deal [Video]

In this episode, I visit with New Yorker reporter Adam Davidson, who penned an article in the New Yorker which looked at a hotel deal between the Trump organization and a family of Politically Exposed Persons (PEPs) in...more

Top Ten International Anti-Corruption Developments for January 2017

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

Insight from the DOJ Fraud Section

Without fanfare, on February 8 the Fraud Section of the Department of Justice (DOJ) published new corporate compliance guidance on its public website. The guidance is presented as a set of topics and questions, entitled...more

First ‘Trial of the Century’ and the SQM FCPA Enforcement Action – Part II

Today I conclude my two-part series on the recent Foreign Corrupt Practices Act (FCPA) enforcement action involving the Chilean chemicals and mining company Sociedad Química y Minera de Chile (SQM), which agreed to pay a...more

New DOJ Evaluation – Valuable Document for the Compliance Practitioner: Part II

Yesterday I began a two-part series on the Department of Justice (DOJ’s) “Evaluation of Corporate Compliance Programs” (Evaluation) posted on the Fraud Section website late last week. The document is an 11-part list of...more

New DOJ Evaluation – Valuable Document for the Compliance Practitioner: Part I

I guess Matt Kelly cannot leave his journalist roots for it was he who broke the story within the greater compliance community that the Department of Justice (DOJ) very quietly released a document, entitled “Evaluation of...more

A ‘Most Daring Act’ and the SQM FCPA Enforcement Action – Part I

A most “daring act” seems to be a good way to introduce a multi-part look at the recent Foreign Corrupt Practices Act (FCPA) enforcement action involving the Chilean chemicals and mining company Sociedad Química y Minera de...more

ENI Receives ISO 37001 Certification and ENI CEO Charged with Corruption

Today’s headline is inspired by two recent notices; the first is from a January 25 ENI Press Release crowing that “Eni is the first Italian company to receive that certification”. The second came from an article in the...more

Yikes: The Perils of Remediation and Corporate Monitors

The Justice Department has raised the stakes on anti-corruption compliance. In other words, DOJ prosecutors expect companies to have more sophisticated and mature compliance programs. If a company walks into the Justice...more

Focus on the Issue of “Corrupt Intent”

Legal and compliance practitioners are often asked to review a set of facts and determine whether the actors will potentially violate the FCPA. A lot has been written on the vagueness or lack of clarity surrounding the FCPA....more

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

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

Top Ten International Anti-Corruption Developments for December 2016

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

Serious Fraud Office Makes Big Splash with UK Bribery Act Resolution with Rolls Royce

After years of fits and starts, and promises and disappointments, the Serious Fraud Office and the UK Bribery Act made its initial splash on the anti-corruption enforcement landscape. Since 2011, companies have been...more

FCPA Recidivists: Orthofix (Part II of II)

In its continuing quest to push the message of aggressive FCPA enforcement, the SEC resolved FCPA charges against Orthofix, a medical device company, for $6 million in penalties and disgorgement. In a related action, the SEC...more

Modern Enforcement: Rolls-Royce’s $800 Million Global Settlement

Rolls-Royce plc, a UK-based company that manufactures engines and generators for the aerospace, defense, marine, and energy sectors, has agreed to pay over $800 million to resolve parallel investigations by U.S., UK, and...more

Foreign Corrupt Practices Act 2016 Year-End Update

2016 was a record-setting year for Foreign Corrupt Practices Act (“FCPA”) enforcement, as both the U.S. Department of Justice (“DOJ”) and the U.S. Securities and Exchange Commission (“SEC”) recovered well over $2 billion in...more

Sapin II - France’s War on Corruption

In July 2015, Michel Sapin, the French Minister of Finance, summarized his proposals for a new French law prohibiting corruption and seeking “transparency in economic life”. That law, modeled after the U.S. Foreign Corrupt...more

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