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Deferred Prosecution Agreements The Foreign Corrupt Practices Act

Where O’ Where Did Our Monitors Go? — The Telia Bribery Case

by Michael Volkov on

Just when everyone was anticipating the beginning of an uptick in FCPA enforcement in 2017, the Justice Department and the SEC delivered a resounding message to remind everyone that FCPA enforcement is here to stay. However,...more

The Telia FCPA Resolution: Part V-Lessons Learned

by Thomas Fox on

Today, lessons learned. Over the past several blog posts, I have taken a deep dive into the Telia Company AB (Telia) Foreign Corrupt Practices Act (FCPA) enforcement action. Anytime you have new No. 1 in the all-time FCPA...more

Telia FCPA Enforcement Action: Part IV – Getting Some Monies Back

by Thomas Fox on

I have spent the past few blog posts reviewing the many lessons that can be garnered by the compliance practitioner from the Telia Company AB (Telia) Foreign Corrupt Practices Act (FCPA) resolution. However, there is one...more

The Telia FCPA Resolution: Part III – The Individuals

by Thomas Fox on

I continue my exploration of the Telia Company AB (Telia) Foreign Corrupt Practices Act (FCPA) enforcement action and the parallel actions. Today I will consider the individuals who have been criminally indicted in Sweden and...more

Southern District Of New York Allows Putative Securities Fraud Class Action To Proceed Against Company That Pleaded Guilty To FCPA...

by Shearman & Sterling LLP on

On September 19, 2017, Judge Andrew L. Carter, Jr. of the United States District Court for the Southern District of New York allowed a putative securities fraud class action to proceed against VEON Ltd. (“VEON”), a...more

The Telia FCPA Resolution: Part II – The Bribery Schemes

by Thomas Fox on

Over the next few blog posts, I will be exploring the resolution and what lessons the compliance practitioner can draw from the Telia Company Foreign Corrupt Practices Act, (FCPA) enforcement action, the parallel actions and...more

The Telia FCPA Resolution, Part I

by Thomas Fox on

While the resolution of the Telia Company (Telia) Foreign Corrupt Practices Act (FCPA) matter has long been awaited, the results announced yesterday by the Department of Justice (DOJ) and Securities and Exchange Commission...more

Foreign Corrupt Practices Act 2017 Mid-Year Update

by BakerHostetler on

The first half of 2017 has been eagerly anticipated following the record-setting year in 2016 for Foreign Corrupt Practices Act (“FCPA”) enforcement by both the U.S. Department of Justice (“DOJ”) and the U.S. Securities and...more

Top Ten International Anti-Corruption Developments for July 2017

by Morrison & Foerster LLP on

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

Lessons in Failures of Internal Controls

by Thomas Fox on

Last week’s announcement by the Securities and Exchange Commission (SEC) of the resolution of its outstanding Foreign Corrupt Practices Act (FCPA) enforcement action with Halliburton Company continues to resonate and provide...more

White Collar Watch (July 2017 • Vol 1, Issue 2)

by Blank Rome LLP on

Welcome to the summer edition of Blank Rome’s White Collar Watch. In a world that seems to bring new challenges daily—such as the global cybersecurity attacks that were launched in late June—this newsletter is designed to...more

Oh, Hadn’t You Heard? You’re Violating French Law Right Now! France Gets Serieuse about Anti-Corruption

Ok, ok, don’t panic. Maybe not all of the millions of dedicated readers of this blog are in violation. Nevertheless, as of June 1, if your company does business in France, it may be time to check your anticorruption...more

FCPA Digest - July 2017 - Recent Trends and Patterns in the Enforcement of the Foreign Corrupt Practices Act

by Shearman & Sterling LLP on

Shearman & Sterling’s bi-annual Trends & Patterns in FCPA Enforcement report provides insightful analysis of recent enforcement trends and patterns in the US, the UK and elsewhere, as well as helpful guidance on emerging best...more

Red Notice Newsletter - June 2017

ANTICORRUPTION DEVELOPMENTS - Linde Group Receives DOJ Declination Pursuant to FCPA Pilot Program - On June 16, 2017, German based chemical and gas company Linde Group’s American affiliates, Linde North America Inc....more

Top Ten International Anti-Corruption Developments for May 2017

by Morrison & Foerster LLP on

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

Top Ten International Anti-Corruption Developments for April 2017

by Morrison & Foerster LLP on

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

Transparency in FCPA Enforcement

by Michael Volkov on

We all value transparency as a general concept, especially when it comes to the government. In a real macro perspective, we fund the government and we demand that our government operate efficiently, effectively and ethically....more

The New Faces of FCPA Enforcement: The Transition to a Sessions-Clayton Enforcement Regime Is Unlikely to Result in Drastic...

by K&L Gates LLP on

Now that the Trump administration has passed its first 100 days, some additional insights are available with respect to how the administration plans to enforce anti-corruption laws, including the Foreign Corrupt Practices Act...more

A Judicial Take On SFO Investigative Powers

by Morrison & Foerster LLP on

The High Court of Justice of England and Wales (“The High Court”) recently provided a rare insight into the difficulties that companies and individuals may face when challenging the basis of a Serious Fraud Office (“SFO”)...more

Code of Conduct Week: Part I – Introduction

by Thomas Fox on

I am joined by Eric Morehead as we begin a five-part series on the Code of Conduct, which serves as the foundational document of a compliance program. Morehead is well-known within the compliance community, having worked at...more

Investor Suits Follow in the Wake of Western Union Settlement of Money Laundering and Fraud Claims

by Ballard Spahr LLP on

On January 19, 2017, the Western Union Company (“Western Union” or the “Company”) entered into a deferred prosecution agreement (“DPA”) with the Department of Justice (“DOJ”), in which Western Union admitted to willful...more

French Anti-Corruption Law Reform

Despite signing the OECD anti-corruption Convention in 1997, France has long been perceived as lacking necessary tools for domestic and international anti-corruption enforcement, particularly in comparison to the US Foreign...more

Top Ten International Anti-Corruption Developments for January 2017

by Morrison & Foerster LLP on

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

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

by Thomas Fox on

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

The Embraer FCPA Enforcement Action

by Thomas Fox on

The Department of Justice (DOJ) and Securities and Exchange Commission (SEC) continued their stunning 2016 run of Foreign Corrupt Practices Act (FCPA) decisions with the announcement of the resolution of the Embraer SA...more

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