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Top Ten International Anti-Corruption Developments for April 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

Dorsey Anti-Corruption Digest - April 2016

Welcome to Dorsey & Whitney’s monthly Anti-Corruption Digest. In this digest, we draw together news of enforcement activity throughout the world and aim to reduce your information overload. Our London, Minneapolis, New York...more

A transatlantic consideration of recent developments in corporate self-reporting

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

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

Fokker: No Judicial Oversight of Deferred Prosecution Agreements

The D.C. Circuit dealt a blow last week to judicial attempts to exercise supervision over Justice Department negotiated Deferred Prosecution Agreements. In United States v. Fokker, the Court answered the question in a...more

Indiana Medical Device Manufacturer’s Deferred Prosecution Agreement with DOJ Extended for a Second Time

On March 25, an Indiana-based medical device manufacturer announced that the deferred prosecution agreement it entered into with the DOJ to settle FCPA charges in 2012 would be extended a second time. The company reported...more

Joint Enforcement of the Anti-Kickback Statute and the Foreign Corrupt Practices Act

On March 1, 2016, the Department of Justice (“DOJ”) announced that Olympus Corporation of the Americas (“Olympus”) entered into two deferred prosecution agreements with DOJ, under which Olympus will pay a total of $646...more

Australia Raises its Anti-bribery Compliance & Enforcement Game

After broad international and domestic criticism of its efforts, the Australian Government is now showing an appetite for significant reform in the area of foreign bribery....more

Compliance Lessons from the Olympus Corporate Integrity Agreement – Part I

The recent Olympus Corporation and related entities (collectively ‘Olympus’) enforcement action demonstrated a company seemingly dedicated to lying, cheating and stealing its way across the globe in search of almighty dollar....more

The Olympus Debacle: Why Internal Whistleblowing is a Good Thing for Compliance

The U.S. Department of Justice announced last week that Olympus Corporation of the Americas (OCA) agreed to pay $646 million to resolve three cases relating to its longstanding practice to bribe doctors and hospitals in the...more

Medical Device Subsidiary Agrees to DPA with DOJ Related to Health Care Bribes

On March 1, a Miami-based medical device company entered into a deferred prosecution agreement (DPA) to resolve charges of conspiracy to violate the FCPA and violating the FCPA in connection with improper payments and...more

Olympus Settles FCPA Charges with DOJ

The Department of Justice resolved another FCPA investigation centered on payments made to health officials. Olympus Corporation of the Americas, a wholly owned subsidiary of Olympus Corporation, Tokyo, Japan, and Olympus...more

Olympus: A Culture of Bribery and Kickbacks

When compliance officers read about a major Justice Department settlement action, we can all hear the collective sigh of relief – “Thank goodness, that did not happen here in my company.”...more

Massachusetts-Based Technology Company and Two Chinese Subsidiaries Pay $28 Million to Settle Civil and Criminal FCPA Charges; SEC...

On February 16, the SEC and DOJ announced a settlement with a Massachusetts-based technology company for violations of the FCPA. The technology company and two Chinese subsidiaries agreed to pay $28 million to settle the...more

A Teaching Moment Inside VimpelCom’s Boardroom

The VimpelCom FCPA settlement underscored the importance of Compliance 2.0 and the need to reform board deliberations and governance. No one can read the facts without shaking their heads and asking – what was the VimpelCom...more

VimpelCom's Global FCPA Settlement - A Multinational Resolution

The U.S. Department of Justice (DOJ), the U.S. Securities and Exchange Commission (SEC) and the Public Prosecution Service of the Netherlands (OM) announced a coordinated criminal and civil Foreign Corrupt Practices Act...more

Key Takeaways From This Year’s Early FCPA Enforcement Actions

February has been a big month for U.S. Foreign Corrupt Practices Act (FCPA) enforcement. It started with the U.S. Securities and Exchange Commission (SEC) quietly resolving a string of relatively small matters. Then, at the...more

VimpelCom Final Thoughts

Today, I conclude my exploration of the VimpelCom Foreign Corrupt Practices Act (FCPA) enforcement action. As I said yesterday, this case will be studied for some time as a textbook example of bribery schemes used...more

Yates Memo in Action: No Cooperation Credit in FCPA Enforcement for Failing to Disclose Key Facts

A recent case illustrates both the ongoing corruption risks for U.S. companies doing business in developing countries such as China and the Government’s tougher stance on settling white collar crime cases. In this case, the...more

U.S. FCPA Enforcement in China: The SEC's First DPA with a Chinese Citizen

On February 16, 2016, the U.S. Department of Justice ("DOJ") and Securities and Exchange Commission ("SEC") announced their newest settlements regarding violations of the U.S. Foreign Corrupt Practices Act ("FCPA"). The DOJ...more

VimpelCom Settles FCPA Case – Part III

Today, I continue my exploration of the lessons to be learned from the VimpelCom Ltd. (VimpelCom) Foreign Corrupt Practices Act (FCPA) enforcement action. While it is clear that the company and its Uzbeki subsidiary, Unitel...more

PTC Settlement: Compliance Reminders for Internal Controls, Travel and Gifts

PTC, a Massachusetts software company, reached settlements with the SEC and DOJ last week for FCPA violations for a total of $28 million. Interestingly, the SEC announced a DPA with a PTC official who assisted in the...more

A 'Very Different Picture': Landmark FCPA Corporate Settlement After Relatively Slow 2015 Enforcement

When asked about the relatively slow year of Foreign Corrupt Practices Act (“FCPA”) prosecutions in 2015, the Chief of the DOJ Criminal Division’s Fraud Section suggested last month: “one year isn’t long enough to tell the...more

VimpelCom Settles FCPA Case – Part II

Today, I continue my exploration of the resolution documents from the long-standing Foreign Corrupt Practices Act (FCPA) probe into the Dutch telecom giant VimpelCom Ltd. (VimpelCom) for a spectacular, long-standing bribery...more

The Force Awakens: Vimpelcom’s FCPA Settlement and the Wreckage Left Behind (Part II of II)

The Vimpelcom FCPA enforcement action is stunning in its breadth and the brazen nature of the bribery scheme. It is hard to accept that such conduct stretched into 2011 to 2013, given the significant emphasis placed on...more

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