Podcast - Risk Management: Revised FCPA Corporate Enforcement Policy
This Week in FCPA-Episode 80, The Last Jedi Edition
FCPA Compliance Report-Episode 346, Mike Skopets on Miller’s Summer 2017 FCPA Report
FCPA Compliance Report-Episode 345-Mike Volkov on Linde Gas and CDM Smith declinations
This Week in FCPA-Episode 58, the Declination Edition
Compliance into the Weeds-Episode 43, the Linde Declination
This Week in FCPA-Episode 56
FCPA Pilot Program
Everything Compliance-Episode 11, the first 100 Days of the Trump Administration, Part II
FCPA Compliance Report-Episode 325, Miller & Chevalier Report on Declinations
On April 15, 2024, the U.S. Department of Justice (DOJ) Criminal Division launched a new pilot program to enable whistleblowers to avoid prosecution when they voluntarily report new information to federal law enforcement...more
The U.S. Department of Justice (DOJ) recently announced a rare criminal indictment involving the Medicare Advantage program—a contrast from DOJ’s more typical use of its civil enforcement authority to pursue similar issues...more
On January 17, 2023, Assistant Attorney General Kenneth A. Polite, Jr. (AAG Polite) announced changes to the Department of Justice’s (DOJ) FCPA Corporate Enforcement Policy (CEP). The CEP, which applies to all Criminal...more
The U.S. Department of Justice (DOJ), through Assistant Attorney General Kenneth A. Polite Jr., announced on Jan. 17, 2023, "the first significant changes" to its Corporate Enforcement Policy (CEP) since 2017. The revisions...more
Happy New Year!! In the FCPA arena, 2019 was a record year – in enforcement and compliance. Many continuing trends are becoming more than trends – meaning they are turning into established practices....more
In the first corporate FCPA action of 2019, Cognizant Technology Solutions Company settled its long-running FCPA case, agreeing to pay the SEC $25 million....more
Despite predictions of a slow-down in enforcement under the Trump administration—and indications that enforcement in some areas has decreased in the past year1—2018 was yet again an active year for FCPA enforcement. The year...more
ANTICORRUPTION DEVELOPMENTS - $34 Million SEC Settlement for Legg Mason - On August 27, 2018, the Securities and Exchange Commission (SEC) announced that Legg Mason Inc. will pay more than $34 million to settle an...more
Keeping ahead of global anti-corruption trends is critical in today’s business markets. The Dorsey Anti-Corruption Digest, which puts global trends at your fingertips, puts you ahead. The deep experience of the Dorsey...more
Deputy Attorney General Rod J. Rosenstein recently announced a revision to the U.S. Department of Justice (“DOJ”) policy on corporate enforcement of the Foreign Corrupt Practices Act (“FCPA”). The revision codifies a pilot...more
In this episode, I visit with Mike Skopets, from Miller & Chevalier on the firm’s Summer 2017 FCPA Report. We discuss the background to the Report and begin with what macro trends the firm identified. We discuss the numbers...more
The Department of Justice (DOJ) ended its probe of Net1 UEPS Technologies, according to SEC filings from the South African-based payment processing company. The company received a declination from the Securities and Exchange...more
Welcome to Dorsey & Whitney’s monthly Anti-Corruption Digest. The Digest puts material regarding anti-corruption enforcement from around the world at your fingertips, keeping you ahead of critical events that impact global...more
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
Every life sciences company with international operations should have a robust Foreign Corrupt Practices Act (FCPA) compliance program as part of its overall compliance strategy. On April 5, 2016, the Justice Department...more
More carrot, less stick? On 5 April 2016, the Fraud Section of the US Department of Justice’s (DOJ) Criminal Division issued an Enforcement Plan and Guidance (the DOJ Guidance), setting out the steps that it is taking to...more
On April 5, 2016, the Department of Justice’s (“DOJ”) Fraud Section Chief, Andrew Weissmann, issued a memo (the “Weissmann Memorandum”) announcing a one-year Pilot Program that offers a carrot and stick approach to...more
On April 5, 2016, the Fraud Section of the Department of Justice's (DOJ) Criminal Division issued an enforcement plan and guidance (the Guidance) laying out three steps it is taking to intensify Foreign Corrupt Practices Act...more
On September 9, 2015, the U.S. Department of Justice issued guidance regarding the prosecution of individuals in cases involving criminal and civil corporate wrongdoing. The first major policy memorandum issued since Attorney...more
The Department of Justice has released a new policy intended to further the Department’s effort to hold individuals accountable for corporate wrongdoing. The policy was laid out in a September 9, 2015 memorandum authored by...more
We are pleased to share with you BakerHostetler's 2013 Mid-Year Foreign Corrupt Practices Act Update, which offers a summary of the following: - Company prosecutions; - Declinations; - Completed trials; ...more