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Criminal Penalties Foreign Corrupt Practices Act (FCPA)

Benesch

White Collar Quarterly Report | Q1 2024

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We are thrilled to introduce the inaugural issue of our quarterly White Collar newsletter, a dedicated resource from Benesch’s White Collar, Government Investigations & Regulatory Compliance Practice Group. Each issue...more

The Volkov Law Group

Gunvor Falls Under FCPA Axe and Agrees to Pay Criminal Penalty of $661 Million (Part I of III)

The Volkov Law Group on

You have to give the Justice Department credit — after two slow enforcement years, DOJ is starting off 2024 with a relative “bang;” first, DOJ reached a large settlement with SAP in January, and now, DOJ has reached a...more

Jones Day

FCPA 2023 Year in Review

Jones Day on

Foreign Corrupt Practices Act (“FCPA”) enforcement continues to slowly rebound from pre-pandemic levels. In 2023, the Department of Justice (“DOJ”) and the Securities and Exchange Commission (“SEC”) resolved 13 corporate FCPA...more

Orrick, Herrington & Sutcliffe LLP

DOJ revises corporate enforcement policy applicable to all criminal matters including FCPA cases

On January 17, Assistant Attorney General Kenneth A. Polite, Jr. delivered remarks at Georgetown University Law Center, during which he announced changes to the DOJ’s Criminal Division Corporate Enforcement and Voluntary...more

Thomas Fox - Compliance Evangelist

Profit Sharing as Bribery: The Honeywell FCPA Enforcement Action: Part 3 – The Comeback

To close out 2022 in Foreign Corrupt Practices Act (FCPA) enforcement actions, the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) announced settlements of FCPA enforcement actions with Honeywell UOP,...more

Thomas Fox - Compliance Evangelist

Profit Sharing as Bribery: The Honeywell FCPA Enforcement Action: Part 2 – The King and Bribery Schemes

To close out 2022 in Foreign Corrupt Practices Act (FCPA) enforcement actions, the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) announced settlements of FCPA enforcement actions with Honeywell UOP,...more

Thomas Fox - Compliance Evangelist

Profit Sharing as Bribery: The Honeywell FCPA Enforcement Action: Part 1 – Introduction

To close out 2022 in Foreign Corrupt Practices Act (FCPA) enforcement actions, the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) both announced settlements of FCPA enforcement actions with Honeywell...more

Bass, Berry & Sims PLC

FCPA Enforcement Update: Two Big Settlements to End the Year 

Bass, Berry & Sims PLC on

In the past several years there has been a significant decrease in Foreign Corrupt Practices Act (FCPA) enforcement efforts. Reports suggest that corporate criminal cases have decreased by roughly 50% since 2012. FCPA...more

Thomas Fox - Compliance Evangelist

ABB FCPA Resolution: Part 1 – Introduction

Late last week, the Department of Justice (DOJ) announced a highly anticipated resolution of Foreign Corruption Practices Act (FCPA) violation involving the Swiss construction giant, ABB Ltd. The most obvious significance is...more

Wilson Sonsini Goodrich & Rosati

DOJ Announces New Guidance on Corporate Criminal Enforcement

On September 15, 2022, Deputy Attorney General of the Department of Justice (DOJ) Lisa Monaco announced pivotal new guidance about the DOJ’s corporate criminal enforcement efforts. Her speech, accompanied by a more...more

Thomas Fox - Compliance Evangelist

Glencore Resolution: Part III – The Commodity Price Manipulation Case

Last week, the Attorney General and a host of other Department of Justice (DOJ) officials announced the settlement of a massive Foreign Corrupt Practices Act (FCPA) and market manipulation case against Glencore plc...more

Thomas Fox - Compliance Evangelist

Glencore Resolution: Part II – The FCPA Action

Last week, the Attorney General and a host of other Department of Justice (DOJ) officials announced the settlement of a massive Foreign Corrupt Practices Act (FCPA) and market manipulation case against Glencore plc...more

Thomas Fox - Compliance Evangelist

Glencore FCPA Resolution, Part I-Introduction

“The rule of law requires that there not be one rule for the powerful and another for the powerless; one rule for the rich and another for the poor. The Justice Department will continue to bring to bear its resources on...more

Thomas Fox - Compliance Evangelist

Cookies, Chocolates and IP: The Stericycle FCPA Enforcement Action – Part IV

Last week, the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) announced a Foreign Corrupt Practices Act (FCPA) enforcement action, involving the waste management company, Stericycle, Inc....more

McGuireWoods LLP

DOJ and SEC Kick Off the Second Quarter with Major FCPA Settlement with International Waste Management Company

McGuireWoods LLP on

On April 20, 2022, the U.S. Department of Justice (DOJ) and Securities and Exchange Commission (SEC) separately announced that Stericycle Inc. (Stericycle), an international waste management company headquartered in Lake...more

Thomas Fox - Compliance Evangelist

Cookies, Chocolates and IP: The Stericycle FCPA Enforcement Action – Part I

The Department of Justice (DOJ) and Securities and Exchange Commission (SEC) announced a Foreign Corrupt Practices Act (FCPA) enforcement action. To say that the respondent company, Stericycle, Inc. (Stericycle) had a culture...more

Goodwin

2021 Year in Review: FCPA

Goodwin on

A. Basic Overview of Statute - The Foreign Corrupt Practices Act of 1977, as amended, 15 U.S.C. §§ 78dd-1, et seq. (FCPA), makes it unlawful for U.S. persons and entities and others who act within the jurisdiction of the...more

Thomas Fox - Compliance Evangelist

2021 – The Year in FCPA Enforcement

There was a paucity of Foreign Corrupt Practices Act (FCPA) enforcement actions in 2021. However, the few enforcement actions announced did provide significant lessons for every compliance professional....more

Thomas Fox - Compliance Evangelist

Foster Wheeler Settles Corruption Allegations – Not a Siren’s Song

Last week, Amec Foster Wheeler Limited (Foster Wheeler) which is currently owned by John Wood Group PLC (Wood), the successor-in-interest to Amec Foster Wheeler Plc., announced that it had settled a long-standing corruption...more

Thomas Fox - Compliance Evangelist

Panasonic Avionics Whistleblower Award

Last week a major Securities and Exchange Commission (SEC) whistleblower award of $28 million was announced (SEC Award). Although the names of the parties were redacted, the law firm which represented the whistleblower...more

WilmerHale

Latin America Anti-Bribery Year-in-Review: 2020 Developments and Predictions for 2021 (Spanish version)

WilmerHale on

A pesar de los impactos de la pandemia del COVID-19, 2020 fue un año activo no solo para la aplicación de la Ley de Prácticas Corruptas Extranjeras (Foreign Corrupt Practices Act, FCPA), sino también para la lucha contra la...more

WilmerHale

Latin America Anti-Bribery Year-in-Review: 2020 Developments and Predictions for 2021

WilmerHale on

Despite the impacts of the COVID-19 pandemic, 2020 was an active year for Foreign Corrupt Practices Act (FCPA) enforcement - and anti-corruption enforcement more generally. Enforcement actions related to Latin America played...more

King & Spalding

What’s in Store for White-Collar Enforcement in 2021 and Beyond

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Federal white-collar prosecutions declined considerably from 2010 to 2019, and likely fell even further last year after courts and government offices closed. But given the impending end of the pandemic, another surge of...more

Thomas Fox - Compliance Evangelist

Boeing Fraud Enforcement Action: Part 3 – Remediation and Going Forward

This week I am considering the recent settlement by the Department of Justice (DOJ) with The Boeing Company (Boeing) around its fraud in the certification of its 737 MAX aircraft. The resolution was via a Deferred Prosecution...more

ArentFox Schiff

Deutsche Bank DPA Reflects Government’s Focus on Third-Party Risk Management and Data-Driven Compliance Programs

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On January 8, 2021, US authorities announced that they reached an agreement with Deutsche Bank Aktiengesellschaft (Deutsche Bank) to resolve the government’s investigation into violations of the Foreign Corrupt Practices Act...more

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