Episode 333 -- The Boeing Proposed Plea Agreement
2 Gurus Talk Compliance: Episode 26 – The Compliance Week Wrap Up Edition
Episode 305 -- Deep Dive into SAP FCPA Settlement
Corruption, Crime, and Compliance - The Ericsson FCPA DPA Breach Settlement
Episode 258 -- Deep Dive into ABB FCPA Settlement
What DAG Lisa Monaco's Speech Means for Compliance Programs
Federal Monitorships and Making Them Work
FCPA Compliance Report - James Koukios on the Monaco Speech
Compliance Into The Weeds: DAG Announces Changes in Enforcement Priorities
Episode 160 -- A Deep Dive into the Herbalife FCPA Settlement
Everything Compliance-Episode 57-the Airbus edition
Episode 119 -- The Ericsson FCPA Settlement
Episode 117 -- FCPA Update: Samsung FCPA Settlement; Braskem Former CEO Indicted; Transport CEO Convicted after Trial
This Week in FCPA-Episode 96, 2018 - the Opening Day edition
FCPA Compliance and Ethics Report-Episode 134, Judge Rakoff, Judge Leon and their comments on DPAs, with the FCPA Professor
FCPA Compliance and Ethics Report Episode 129-Judge Rakoff, Judge Leon and Individual Prosecutions Under the FCPA
FCPA Compliance and Ethics Report-Episode 118-the Alstom FCPA Enforcement Action
FCPA Compliance and Ethics Report-Episode 31-the FCPA Year in Review, Corporate Enforcement Actions
FCPA Compliance and Ethics Report-Episode 30-Interview with the FCPA Professor-Part 2
FCPA Compliance and Ethics Report-Episode 29-Interview with the FCPA Professor-Part 1
On April 15, the U.S. Department of Justice released The Criminal Division’s Pilot Program on Voluntary Self-Disclosures for Individuals (the “Pilot”) designed to encourage individuals to report certain types of criminal...more
On April 15, the U.S. Department of Justice released The Criminal Division’s Pilot Program on Voluntary Self-Disclosures for Individuals (the Pilot) designed to encourage individuals to report certain types of criminal...more
On January 10, when announcing his office’s new Whistleblower Pilot Program, Southern District of New York United States Attorney Damian Williams told potential cooperators “[c]all us before we call you.” But should you? ...more
In January 2023, the Criminal Division of the Department of Justice (DOJ) announced revisions to its Corporate Enforcement Policy (CEP), which we previously summarized here and discussed in further detail as part of...more
We continue our exploration of the SAP Foreign Corrupt Practices Act (FCPA) enforcement action. Today we go full geek in a look at the fine and penalty and most importantly what the fine and penalty communicate about what the...more
Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption law and enforcement developments from the past...more
On November 28–30, 2023, the American Conference Institute’s 40th International Conference on the Foreign Corrupt Practices Act (“FCPA”), held in Washington, D.C., brought together prosecutors, regulators, corporate...more
Recent guidance from the US Department of Justice (DOJ) reflects its continued focus on corporate compensation structures to promote compliance. In the past few months, the DOJ has entered into settlement agreements that...more
In February 2023, the US Department of Justice (DOJ) announced a formal Voluntary Self-Disclosure Policy (the DOJ Policy) that reinforces a memorandum issued by Deputy Attorney General Lisa Monaco directing US Attorney’s...more
On January 17, 2023, Assistant Attorney General Kenneth A. Polite, Jr. (“AAG Polite”) announced several key revisions to the Department of Justice (“DOJ”) Criminal Division’s Corporate Enforcement Policy (the “CEP”) governing...more
On September 15, 2022, the Department of Justice (“DOJ”) announced several important changes to its policies for prosecuting corporate crime. Deputy Attorney General Lisa O. Monaco, who made the announcement in a speech at...more
The Superior Court of Québec recently published its reasons1 approving Canada’s first remediation agreement under the Criminal Code, which is Canada’s version of a deferred prosecution agreement (DPA). In his reasons, the...more
On March 2, Ericsson, the Swedish networking and telecommunications company, reported that the Department of Justice (DOJ) has accused the company of violating its 2019 Deferred Prosecution Agreement (DPA) by failing to...more
We are the end of my multi-part exploration of the Herbalife Nutrition Ltd (Herbalife) Foreign Corrupt Practices Act (FCPA) enforcement action with both the Department of Justice (DOJ) and Securities and Exchange Commission...more
Last week the Justice Department (DOJ) announced a resolution of the long stand Foreign Corrupt Practices Act (FCPA) enforcement action involving Telefonaktiebolaget LM Ericsson (Ericsson), a multinational networking and...more
As widely anticipated, French and U.K. regulators recently published guidance detailing their expectations for corporate cooperation in enforcement investigations. Both sets of guidance demonstrate further alignment of those...more
November begins the final push for the compliance conference season, which customarily ends with the ACI National FCPA Conference. During November and into early December, Department of Justice (DOJ) officials have...more
“Official Acts”—What They Are… and Are Not - Why it matters: On June 27, 2016, the Supreme Court decided McDonnell v. U.S., holding that, for purposes of the federal public corruption statutes, an “official act”...more
In 2015, the Department of Justice (DOJ) made more news for the corporate Foreign Corrupt Practices Act (FCPA) cases that it did not bring than for the two that it did bring: Nine times last year, DOJ declined to join...more
In this episode, I review the corporate FCPA enforcement actions of 2013. ...more
In the two most recent corporate Foreign Corrupt Practices Act (FCPA) enforcement actions, the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) to communicate not only what they believe constitutes a...more