Corruption The Foreign Corrupt Practices Act

News & Analysis as of

LATAM/LAN FCPA Enforcement Action, Part I-Some Questions

What is the cost of a Foreign Corrupt Practices Act (FCPA) violation? One subset of that question is what is the cost of not cooperating and not remediating during the pendency of such investigations? Those were two of the...more

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

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

Farewell to Ralph Stanley and a Success in Repatriation

Yesterday I honored Scotty Moore, the lead guitarist for Elvis Presley, who died last week. Today I want to pay homage to another equally large giant from the world of music who recently died, Ralph Stanley. Stanley,...more

The Only Thing You Have to Fear . . . Is No Documentation

Compliance is a profession that requires multi-tasking – another profound grasp of the obvious. But in the multi-tasking world, some principles and strategies are more important than others. My colleague and...more

Battle of the Somme Week – Part I: The Analogic FCPA Enforcement Action

I have not written much in honor of the centennial of the First World War (WWI). However this week I will to remedy this oversight by focusing on the Battle of the Somme, leading up to the first day of the long battle, which...more

Compliance Training – Part II: Risk Ranking and Design

Yesterday I began what I thought would be a two-part series on compliance training.However, or perhaps more accurately, as usual, I got carried away so I am now off on a multi-part series on how to design, implement and...more

The Damaging Myth of the Rogue Employee

As long as 24 years ago, Lynn S. Paine wrote about the myth of the rogue employee in the Harvard Business Review (HBR), in an article entitled “Managing for Organizational Integrity”. In this article she wrote, “executives...more

How to garner a NPA and Declination: Akamai and Nortek – Part III

Today I conclude my three-part series on the Nortek, Inc. (Nortek) and Akamai Technologies, Inc. (Akamai) Foreign Corrupt Practices Act (FCPA) enforcement actions. These enforcement actions resulted in excellent results for...more

China Law Update: Judicial Interpretation on Corruption and Bribery Crimes

On April 18, 2016, the Chinese Supreme People's Court and the Chinese Supreme People's Procuratorate jointly issued the Interpretation of Several Issues concerning the Application of Law in Handling Criminal Cases related to...more

Global Standardization of Enforcement

Maybe I am a Luddite; maybe I just do not understand the new world and the impact of globalization. New ideas do not scare me, like others we know. New ideas present real opportunities for progress and innovation....more

Corruption Risks and Corporate Social Responsibility Spending

Global companies have been embracing socially responsible spending projects to build stronger relationships with local communities. The idea makes a lot of sense and real projects can result in real benefits....more

Joe Howell on the PCAOB, Audits and Compliance – Part IV

This week I have been exploring the Public Accounting Oversight Board (PCAOB) with Joe Howell, an Executive Vice President (EVP) with Workiva Inc. We have considered how some of the issues addressed by the PCAOB directly...more

Joe Howell on the PCAOB, Audits and Compliance – Part III

Today, I continue my exploration with Joe Howell about the Public Accounting Oversight Board (PCAOB), its scrutiny of public company auditors and how its work impacts the corporate compliance function. Yesterday, I ended with...more

The FCPA and SOX and Internal Controls – Twin Sons of a Different Mother?

What is the interplay of two different pieces of legislation enacted almost 25 years apart in response to widely different crisis? In the case of the Foreign Corrupt Practices Act (FCPA) and Sarbanes-Oxley Act (SOX) quite a...more

What Can You Learn in the First Inning?

You might figure that the year I decide to jump back on the Houston Astros bandwagon, they go back in the tank. Last year they were one game away from the American League (AL) Championship. This year they have the third worst...more

Quid Pro Quo and FCPA Enforcement

Yesterday on the podcast, the FCPA Compliance and Ethics Report, I posted the full oral argument from the Supreme Court in the case of McDonnell v. US (shout out to Web Hull for sending it to me), which is the appeal of the...more

What is a Compliance Evangelist?

What does it mean to be the Compliance Evangelist? A colleague put that question to me last week. This friend is a loyal and long time reader of my blog and listener of my podcast and I thought if it was not clear to her,...more

Focus on Corruption: Myanmar - A New Beginning?

Historically, Myanmar has not been known as a country with a focus on anti-corruption and anti-money laundering. In 2015, the Frankfurt-based Transparency International ranked the country as one of the most corrupt places to...more

U.S. - India Newsletter Vol. 2016, Issue 2

Welcome to the second issue of our newsletter, which features news and articles of interest from Pepper’s U.S.-India Practice. In the first quarter of 2016, we saw a lot of activity in the international data privacy...more

Tribute to Dr. Jannetta and Improvisation in Compliance

It is rare you are able to write about someone who directly changed the quality of your life. Rarer yet that you did not know about him, only what he created, until you read his obituary. That happened to me recently when I...more

Is the DOJ’s New FCPA Pilot Program an Offer You Can’t Refuse?

Earlier this month, Assistant US Attorney Leslie Caldwell announced that the US Department of Justice’s Criminal Division Fraud Section will try to entice companies to self-report potential FCPA issues. The DOJ included...more

DOJ Criminal Division Launches One-Year Pilot Program as Part of Enhanced FCPA Enforcement Strategy

On April 5, 2016, the Department of Justice (“DOJ”) Criminal Division’s Fraud Section released a memorandum setting out “three steps” in its “enhanced” enforcement of the Foreign Corrupt Practices Act (“FCPA”). See Apr. 5,...more

Organizational Cultures of Corruption

The following guest post is by Alison Taylor. My new issue brief, published by the Columbia Law School Center for the Advancement of Public Integrity, is based on extensive academic research, a review of primary data...more

Foreign Corrupt Practices Act 2015 Year-End Update

Both the United States Department of Justice (DOJ) and the United States Securities and Exchange Commission (SEC) have continued their focus on anticorruption enforcement in 2015. Although there was a decline in enforcement...more

New DOJ Guidance and FCPA Pilot Program – Part III: Ongoing Remediation

I continue my exploration of the implications from the Department of Justice (DOJ) announcement last week of a new program around Foreign Corrupt Practices Act (FPCA) enforcement, the “Pilot Program”. Contemporaneously, the...more

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