News & Analysis as of

Department of Justice (DOJ) Foreign Corrupt Practices Act (FCPA) Internal Controls

Thomas Fox - Compliance Evangelist

The FCPA Survival Guide

I am thrilled to announce my first podcast series based on a book I have written. The book and the podcast series are titled FCPA Survival Guide and Ethico sponsors. The book is available in the Kindle format, and you can...more

Thomas Fox - Compliance Evangelist

Ten Top Lessons from Recent FCPA Settlements-Lesson No. 9, Internal Controls

Over the past 15 months the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) has made clear through three Foreign Corrupt Practices Act (FCPA) enforcement actions and speeches, their priorities in...more

Thomas Fox - Compliance Evangelist

Operationalizing Compliance Through Payroll

One of the areas articulated in the 2023 ECCP was around payments and payroll. For the both the compliance professional and the corporate payroll function, there is a significant role to play in the operationalization of a...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for November 2023

Morrison & Foerster LLP on

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

American Conference Institute (ACI)

[Event] 40th International Conference on the FCPA - November 28th - 30th, National Harbor, MD

Hosted by American Conference Institute, the 40th International Conference on the FCPA returns for another exciting year with curated programming that shines a global spotlight on anti-corruption compliance challenges,...more

Thomas Fox - Compliance Evangelist

Albemarle FCPA Enforcement Action: Part 4 – Internal Control Failures

Albemarle Corporation (Albemarle), recently agreed to pay more than $218 million to resolve investigations by the U.S. Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) into violations of the...more

Porter Hedges LLP

ComEd Settlement Proves the Foreign Corrupt Practices Act Is Not Limited to Foreign Corruption

Porter Hedges LLP on

On September 28, 2023, the Securities and Exchange Commission (“SEC”) announced that it reached a settlement with Exelon Corporation and its subsidiary, Commonwealth Edison Company (“ComEd”), relating to charges that ComEd...more

The Volkov Law Group

Refreshing and Elevating Your Sanctions Compliance Program (Part II of III)

The Volkov Law Group on

Let’s move beyond the headline – trade compliance is the new FCPA.  We get it.  The next step is to do something about it.  The Justice Department has repeated this refrain – it is one of its greatest hits.  In addition, DOJ,...more

American Conference Institute (ACI)

[Event] Summit on Anti-Corruption & Compliance Programs - March 22nd - 23rd, Mexico City, Mexico

Hosted by American Conference Institute, the Mexico Summit on Anti-Corruption & Compliance Programs returns for another exciting year with curated programming that shines a global spotlight on anti-corruption compliance...more

The Volkov Law Group

The Importance of Accounting and Internal Controls (Part I of II)

The Volkov Law Group on

Here are some basic propositions that surround FCPA compliance. It is often underplayed that the FCPA contains more than just a bribery prohibition – the FCPA contains broad provisions, requiring accurate books and records...more

Thomas Fox - Compliance Evangelist

Everything Compliance - Episode 108 - The ABB Edition

Welcome to the only roundtable podcast in compliance as we celebrate our second century of shows. Everything Compliance has been honored by W3 as a top talk show in podcasting. In this episode, we have the quintet of Jay...more

Thomas Fox - Compliance Evangelist

Oracle: FCPA Recidivist Part 5 – What Does It All Mean?

In this post, we conclude our exploration of the Foreign Corrupt Practices Act (FCPA) enforcement action involving the now recidivist Oracle Corporation. This enforcement action was concluded with the Securities and Exchange...more

American Conference Institute (ACI)

[Event] FCPA & Anti-Corruption for the Life Sciences Industry - July 21st - 22nd, Boston, MA

ACI is excited to welcome you back in-person to the 14th Advanced Forum on FCPA & Anti-Corruption for the Life Sciences Industry, taking place on July 21–22, 2022 in Boston! Legal and compliance professionals from...more

Dechert LLP

Sanctions are “the New FCPA”: A Heightened Focus for DOJ Enforcement

Dechert LLP on

At a New York City Bar Association event on April 27, Deputy Attorney General Lisa Monaco described economic sanctions as “the new FCPA.” Her characterization should put corporate compliance departments on notice. ...more

Morgan Lewis

Due Diligence, Ethics, and Compliance Considerations for Dealmakers

Morgan Lewis on

In recent years, the US Department of Justice (DOJ) and US Securities & Exchange Commission (SEC) have further defined their anti-corruption due diligence and disclosure expectations of acquiring companies pre- and...more

American Conference Institute (ACI)

[Event] 11th Summit on Anti-Corruption Brazil - May 25th - 26th, São Paulo - State of São Paulo, Brazil

Brazil’s Anti-Corruption and Compliance Community Will Gather for Large, 1:1 and Smaller-Group Discussion! As the longest-standing anti-corruption and compliance gathering in Brazil, Summit on Anti-Corruption Brazil is...more

Foley Hoag LLP - White Collar Law &...

Anti-Corruption in 2022: A Look Ahead

This is the second post in this year’s series examining important trends and new development in white collar law and investigations. Our previous post discussed health care enforcement. Up next: trends in tax enforcement. ...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

American Conference Institute (ACI)

[Event] Mexico Summit on Anti-Corruption & Compliance Programs - March 22nd - 23rd, Mexico City, Mexico

Join the Go-To Event of the Year for Mexico’s Anti-Corruption Community. The annual ACI’s Anti-Corruption Summit in Mexico is back to Mexico City on March 22-23, 2022! This is the most important anti-corruption compliance...more

Thomas Fox - Compliance Evangelist

Continuous Improvement of Internal Controls

Cristina Revelo is the Deputy Director, Corporate Monitoring at Affiliated Monitors, Inc (AMI). Her academic background is in Master of Science and Bachelor of Science in Accountancy from the University of Illinois. Her...more

Eversheds Sutherland (US) LLP

Enforcement appears as messages disappear: The perils of personal and ephemeral messaging

On December 17, 2021, a financial institution agreed to pay $200 million in fines to the Securities and Exchange Commission and Commodities Futures Trading Commission for allowing employees to discuss business on their...more

Skadden, Arps, Slate, Meagher & Flom LLP

Practical Steps To Address DOJ Changes to Corporate Enforcement Policies

In one of the first substantive speeches on corporate criminal enforcement under the Biden administration, Deputy Attorney General Lisa Monaco announced on October 28, 2021, several immediate changes to Department of Justice...more

Thomas Fox - Compliance Evangelist

Internal Controls in Compliance: Part 1-What are Internal Controls?

What specifically are internal controls in a compliance program? Internal controls are not only the foundation of a company but are also the foundation of any effective anti-corruption compliance program. The starting point...more

The Volkov Law Group

WPP, the Largest Global Advertising Group, Settles FCPA Charges with SEC for $19.2 Million (Part I of III)

The Volkov Law Group on

After a long hiatus, the SEC announced a settlement with WPP plc, the world’s largest advertising group, for FCPA violations in India, China, Brazil and Peru for $19.2 million.  The SEC’s resolution charges WPP with...more

Thomas Fox - Compliance Evangelist

Foster Wheeler Settles Corruption Allegations – Bada Bing, Bada Bang and Lessons Learned

I conclude my review of the Amec Foster Wheeler (Foster Wheeler) Foreign Corrupt Practices Act (FCPA) enforcement action. Today, I want to close with the result and some key lessons for the 2021 compliance professional. These...more

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