Enforcement Actions Compliance

News & Analysis as of

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

The DOJ’s Self-Disclosure Program Is Not Even Half the Story

Lots of people are talking about the DOJ’s new self-disclosure pilot program, but it was only the last of three steps announced in the DOJ’s Fraud Section FCPA Enforcement Plan and Guidance. One of them has the potential to...more

FINRA Targets AML Programs and “Culture of Compliance” as 2016 Enforcement Priority, Particularly for High-Risk Broker/Dealers

Under Securities and Exchange Commission (“SEC”) authorization, the Financial Industry Regulatory Authority (“FINRA”) is “responsible for regulating (1) all securities firms that do business with the public[,]” (2) key stock...more

This Week In Securities Litigation

Budget hearings were a focus this week as the Chair of the SEC and Chairman of the CFTC visited Capitol Hill. Both sought substantial increases, requesting more money for technology, inspections and enforcement. While the...more

New DOJ Guidance and FCPA Pilot Program – Part II: Cooperation

Today, I continue my exploration of the implications from the Department of Justice (DOJ) announcement last week of a new program around Foreign Corrupt Practices Act (FPCA) enforcement (herein “Pilot Program”)....more

Avoiding the “Al Capone” version of an FCPA enforcement action—Are your internal controls in order?

Notorious gangster Al Capone likely was guilty of numerous crimes, including bootlegging, maintaining a house of prostitution, bribery, racketeering and multiple counts of murder. Yet he was never convicted of those crimes. ...more

This Week In Securities Litigation

The Foreign Corrupt Practices Act was a key focus this week. The DOJ announced a new one year Pilot Program which holds the promise of a significant reduction in penalties if the firm self-reports and takes a series of steps....more

[Webinar] Hot Topics in Anti-Corruption Enforcement and Compliance - April 22nd, 12:00pm, EDT

The Center for Responsible Enterprise And Trade (CREATe.org) and Transparency International-USA (TI-USA), cordially invite you to join us for a briefing to discuss hot topics in international anti-corruption compliance and...more

Novartis FCPA Enforcement Action, Part II

Yesterday, I used a quotation from the Oscar winning animator, Chuck Jones who described two of his well-known creations, Roadrunner and Wily E. Coyote, by referring to philosopher George Santayana’s description of fanaticism...more

Novartis FCPA Enforcement Action, Part I

The philosopher George Santayana is usually best remembered for the pithy saying, ‘Those who cannot remember the past are condemned to repeat it.” Santayana was an essayist, poet, professor and novelist. According to...more

Foreign Corrupt Practices Act Alert

Busy Q1 Yields Several Significant FCPA Resolutions - Overview - On February 19, during the US Securities and Exchange Commission’s (SEC) annual “SEC Speaks” conference, Kara Brockmeyer, Chief of the SEC’s FCPA...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

SEC Touts Continued Uptick in Whistleblower Tips

On Tuesday, March 8, 2016, in conjunction with announcing a recent $2 million whistleblower award, Sean McKessey, Chief of the Office of the Whistleblower, stated that the SEC continues to see “a significant uptick” in the...more

Derailing Internal Reviews, Audits, Assessments and Investigations

Following FCPA enforcement actions provides important insights that can be translated into corporate compliance program best practices. One key element of an effective ethics and compliance program is conducting periodic...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

SciClone Pharmaceuticals: A Textbook Case of FCPA Violations for Gifts, Meals, Entertainment and Travel

The Securities and Exchange Commission continues its steady march as the prominent FCPA enforcement agency against corporations.  The Justice Department has not brought any enforcement actions this year and continues to...more

Reflections on the SEC- FCPA Enforcement Action Against SAP

The Foreign Corrupt Practices Act (FCPA) enforcement journey, which began last summer with the guilty plea of Vicente Garcia for the payment of bribes to obtain contracts in Panama for his employer, SAP International, ended...more

SEC’s First Whistleblower Award to Company Outsider: Game Changer?

The headlines lit up this month when the Securities and Exchange Commission (SEC) issued its first-ever award to a whistleblower who wasn’t employed by the company on which he had blown the whistle. The award was a...more

Health Care Enforcement in 2016: A Look Back on 2015 and Forecasting the Year Ahead

2015 was a year of transition for the U.S. Department of Justice (“DOJ”), with the installation of a new Attorney General, Deputy Attorney General, and several other high-level officials. In January 2015, Andrew Weissmann...more

State Attorneys General Investigations and Enforcement: What to Expect in 2016

In recent years, state Attorneys General (“state AGs”) have significantly increased their investigative and enforcement efforts across a wide range of industries and matters, and these new efforts present a growing challenge...more

The Person (Idea) of the Year – Corporate Ethics and Culture

Each year I have identified the so-called “person” of the year to capture the most significant enforcement and compliance trend. In the past, I have given the award to the Chief Compliance Officer, the Ethics Officer, the...more

FCPA Year for the DOJ in 2015

Foreign Corrupt Practices Act (FCPA) enforcement by the Department of Justice (DOJ) was a bit different in 2015 than the preceding years. Obviously the record fines and penalties of 2014 dropped considerably. Further, there...more

FCPA Enforcement Actions from 2015: SEC – Part II

Yesterday, I began a review of Foreign Corrupt Practices Act (FCPA) enforcement actions by the Securities and Exchange Commission (SEC) where there were no parallel Department of Justice (DOJ) enforcement actions. Today I...more

Top Ten International Anti-Corruption Developments for November 2015

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 in the past month, with links to primary...more

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