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Enforcement Actions Foreign Corrupt Practices Act (FCPA) Internal Controls

The Volkov Law Group

John Deere Reaches $9.9 Million Settlement with SEC over FCPA Violations

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The U.S. Securities and Exchange Commission (“SEC”) recently instituted proceedings against Deere & Company (“John Deere”), a leading global manufacturer of agricultural and heavy machinery, for multiple violations of the...more

WilmerHale

Making the Connection - What Do Recent SEC Enforcement Actions Mean for Cyber Controls?

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On July 18, 2024, the U.S. District Court for the Southern District of New York dismissed most of the claims brought by the Securities and Exchange Commission (the “Commission”) against SolarWinds Corp. and its Chief...more

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

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 5-Lessons Learned

Over the past several blog posts, I have been exploring the Albemarle FCPA enforcement action.  We have explored in some detail the DOJ Non-Prosecution Agreement (NPA) and the SEC Administrative Order(Order). In this final...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

Bradley Arant Boult Cummings LLP

Philips Agrees to Pay $62M to Settle FCPA Books-and-Records Violations from Efforts to Win Chinese Contracts

Koninklijke Philips N.V., a global medical technology manufacturer, recently agreed to pay over $62 million to resolve a Foreign Corrupt Practices Act (FCPA) enforcement action with the Securities and Exchange Commission...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

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

The Volkov Law Group

Oracle’s FCPA Violations: A Lesson in Managing Third-Party Distributor Risks (Part II of II)

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Oracle’s SEC settlement for $23 million underscores the power of the FCPA provisions mandating effective internal controls and accurate books and records.  As everyone knows, these provisions can be applied to a wide-range of...more

Nutter McClennen & Fish LLP

Nutter Securities Enforcement Update: October 1, 2022

The Nutter Securities Enforcement Update is a periodic summary of noteworthy recent securities enforcement activity, settlements, decisions, and charges. ...more

The Volkov Law Group

GOL’s Bribery Schemes Orchestrated by Board Director (Part II of II)

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GOL’s bribery schemes present some interesting lessons.  Interestingly, at the center of the bribery scheme was a member of GOL’s board of directors.  The bribery scheme was motivated by potential legislation that would...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

Pietragallo Gordon Alfano Bosick & Raspanti,...

New York Judge’s Opinion Confirms Broad Reach of FCPA

Takeaway: Judge’s Broad Interpretation of the FCPA’s Internal Controls Provision and jury conviction make this statute ripe for appellate review....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

The Volkov Law Group

KT Corp. Settles SEC FCPA Case for $6.3 Million (Part I of III)

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The SEC announced its first FCPA enforcement action in 2022. South Korean telecommunications company, KT Corporation, agreed to pay $6.3 million to settle FCPA violations.  As part of the settlement, KT Corp. agreed to pay...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

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

The Volkov Law Group

WPP SEC FCPA Enforcement Action: Lessons Learned (Part III of III)

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The SEC’s FCPA enforcement action against WPP presents a number of important lessons learned, ranging from third-party risk management, properly responding to employee complaints and red flags, and failure to integrate...more

The Volkov Law Group

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

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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

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