News & Analysis as of

Enforcement Actions Bribery

Update on Regulatory Compliance in the Global Health Care Industry

by Baker Ober Health Law on

A comprehensive understanding of the constantly evolving layers that make up federal anti-corruption statutes, sanctions regulations and export control restrictions is imperative for both the pharmaceutical and health care...more

Red Notice Newsletter - Chinese

ANTICORRUPTION DEVELOPMENTS - Steven Peikin Reported to Become Co-Director of SEC’s Enforcement Division - On May 26, 2017, The Wall Street Journal reported that recently confirmed Commissioner Jay Clayton will hire...more

Red Notice Newsletter - Russian

ANTICORRUPTION DEVELOPMENTS - Steven Peikin Reported to Become Co-Director of SEC’s Enforcement Division - On May 26, 2017, The Wall Street Journal reported that recently confirmed Commissioner Jay Clayton will hire...more

FCPA Compliance Report-Episode 333, Professor Samuel Buell

by Thomas Fox on

Today I am joined again by Professor Samuel Buell, from Duke University School of Law to discuss a recent paper he co-authored with Rachel Brewster entitled, “The Market for Global AntiCorruption Enforcement“. In the paper...more

"Creating A Risk" Of Bribery Can Violate The FCPA: Low Threshold For SEC Enforcement Actions

by Allen & Overy LLP on

SEC enforcement actions under the U.S. Foreign Corrupt Practices Act have been setting an ever-lower threshold for violations of the FCPA's books and records, and internal controls provisions. Most recently, the SEC has...more

2016 - A Year for the FCPA Record Books & What It Means for Compliance Practitioners

by Thomas Fox on

We have never seen and may well never see again a year of Foreign Corrupt Practices Act corporate enforcements as we did in 2016. ...more

Red Notice Newsletter - May 2017

ANTICORRUPTION DEVELOPMENTS - Steven Peikin Reported to Become Co-Director of SEC’s Enforcement Division - On May 26, 2017, The Wall Street Journal reported that recently confirmed Commissioner Jay Clayton will...more

B/D Executive Pleads Guilty In Bribery Scheme Uncovered by SEC

by Dorsey & Whitney LLP on

A New York public pension fund was at the center of a pay-to-play scheme uncovered by the SEC. The inquiry ended with charges from the Manhattan U.S. Attorney’s Office against a former managing director of a registered...more

This Week in FCPA-Episode 54, the Rubber Match Edition

by Thomas Fox on

This week, Jay and I have a wide-ranging discussion on some of the week’s top compliance related stories. We discuss: 1. Tom reports on Compliance Week 2017? 2. If the DOJ releases new information in the form of the...more

The Foreign Corrupt Practices Act and the New Trump Administration: Your Top Ten Questions Answered

by Foley & Lardner LLP on

Since mid-2000s investigation of Siemens, and the resulting $800 million penalty for violations of the Foreign Corrupt Practices Act (FCPA), the FCPA has been an enforcement priority of the U.S. Government. Although a dip in...more

Red Notice Newsletter - Chinese

Anticorruption Developments - Former Magyar Telekom Executives Reconcile Bribery Charges - April 24, 2017, the US Securities and Exchange Commission (SEC) announced that the Hungarian telecommunications company...more

Wait a Minute – The FCPA Enforcement Sky Did Not Fall?

by Michael Volkov on

No matter what, I am an optimist. A pessimist’s worldview and lifestyle is really unattractive. I would always rather see the glass as half full. Too many in the professional world have confused negative perspectives and...more

What is the Real Risk of an FCPA Enforcement Action?

by Michael Volkov on

When speaking to clients or potential clients, the question of risk of enforcement is the moose on the table. Sometimes, the question gets asked and other times, the subject is never discussed. To be fair, it is not an easy...more

Red Notice Newsletter - April 2017

ANTICORRUPTION DEVELOPMENTS – Former Magyar Telekom Executives Settle Bribery Charges – On April 24, 2017, the Securities and Exchange Commission (SEC) announced that two former executives of Magyar Telekom, a...more

First 100 Days of the Trump Administration and The FCPA – Same As It Ever Was

by Thomas Fox on

Over the weekend, we had the first 100 days of the Trump administration. To commemorate this constructed time for review of any new administration I gathered the Everything Compliance podcast panel of Mike Volkov, Jay Rosen,...more

Every Little Helps with a DPA

by Dechert LLP on

Lord Justice Leveson approved Tesco Store Limited’s (“Tesco”) Deferred Prosecution Agreement (“DPA”) on 10 April 2017, making them the fourth company since November 2015 to enter into a DPA with the UK’s1 Serious Fraud Office...more

The FCPA at 40 – FCPA Enforcement and the International Fight Against Bribery

by Thomas Fox on

In two speeches last week Department of Justice (DOJ) Acting Principal Assistant Attorney General Trevor McFadden addressed multiple topics and issues around the Foreign Corrupt Practices Act (FCPA). The first set of remarks...more

The FCPA Lives On

On Tuesday, April 18, 2017, Acting Principal Deputy Assistant Attorney General Trevor McFadden (the P-DAAG) spoke at the 10th Anti-Corruption, Export Controls & Sanctions Compliance Summit in Washington, D.C. After much...more

Long-Running Corruption Scheme Exposed in Brazil: Operation "Exposed Invoice" Provides Continuous Improvement Opportunity for...

by Pepper Hamilton LLP on

A massive scheme involving medical products sales to Brazilian public entities has led to recent high-profile arrests. The events highlight the importance to a well-functioning compliance program of keeping up with new...more

This Week In Securities Litigation

by Dorsey & Whitney LLP on

In a holiday shortened week the Commission began preparation for argument before the Supreme Court in an action which could have a significant impact on its enforcement program. The question for resolution is whether the...more

Red Notice Newsletter - March 2017

Anticorruption Developments - SEC Chairman Nominee Jay Clayton Receives Confirmation Hearing - On March 23, 2017, SEC Chairman Nominee Jay Clayton testified before the Senate Banking Committee at his confirmation...more

FCPA Remediation Focus on Supervisory Personnel

by Michael Volkov on

The Justice Department’s FCPA enforcement and remediation focus on supervisory personnel is an interesting development. On the one hand, DOJ has been slow to bring individual criminal enforcement actions for FCPA...more

LRN Compliance Program Effectiveness Report: Part I (and Farewell to Chuck Berry)

by Thomas Fox on

Last week I interviewed Susan Divers, Senior Advisor at LRN Corporation, on the company’s 2016 Ethics and Compliance Program Effectiveness Report (Report). The Report was a fascinating review of the evolution of compliance...more

FCPA: 2016 Year in Review & 2017 Enforcement Predictions

by Bass, Berry & Sims PLC on

Bass, Berry & Sims announces the release of its "FCPA: 2016 Year in Review & 2017 Enforcement Predictions," a review of trends and developments in FCPA as well as a look ahead into what to expect for 2017. The newly released...more

The General Cable FCPA Enforcement Action

by Thomas Fox on

The Department of Justice (DOJ) and Securities and Exchange Commission (SEC) continued their stunning run of 2016 Foreign Corrupt Practices Act (FCPA) enforcement actions right up to the end of the year with the announcement...more

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