FCPA Compliance and Ethics Report-Episode 32-the FCPA Year in Review, Individual Enforcement Actions
Trends in FCPA Compliance and Enforcement for 2014
What Is Driving Stepped Up Government Health Care Enforcement? – Interview with Hope Foster, Member, Mintz Levin
SEC News - Five Year Enforcement Limitation, FCPA Charges for Foreign Nationals, More...
Should Wall Street Fear Mary Jo White?
What matters were you particularly proud to have been involved in during your time at the DoJ?
I’m proud of all of it but I think there are probably a couple of specific matters that stand out in my mind. The first...more
The Justice Department and the financial regulatory agencies have sent a strong message of enforcement, suggesting that financial institutions are not adequately implementing AML compliance controls....more
The Foreign Corrupt Practices Act (FCPA) prohibits giving or offering anything of value to any foreign official with a corrupt intent to assist in obtaining or retaining business. Enforcement of FCPA compliance by the...more
On March 20th and 21st, U.S. regulators, practioners, and other anti-corruption industry professionals gathered in Washington, D.C. for the Second Annual Global Anti-Corruption Congress. The Congress featured speakers,...more
You can learn a lot from other people’s mistakes. We all know that.
In our FCPA world, we have a new poster child for blundering – Alstom. The handwriting is on the wall – as time goes on, the Justice Department is...more
The 2013 calendar year saw several significant developments in the enforcement of the Foreign Corrupt Practices Act (FCPA). The United States Department of Justice (DOJ) and Securities and Exchange Commission (SEC) combined...more
On March 17, Senator Elizabeth Warren (D-MA) and Representatives Elijah Cummings (D-MD) and Maxine Waters (D-CA) sent a letter requesting a meeting with Attorney General Eric Holder to review the findings of a recent report...more
On March 13, the DOJ Office of Inspector General (OIG) issued a report on its audit of the DOJ’s efforts between 2009 and 2011 to pursue alleged mortgage fraud. Of particular note, the report reveals for the first time...more
CD: Could you outline some of the key trends you are seeing in securities litigation and enforcement? Has the volume of class actions in this area increased in recent years?
Jeff E. Butler: One important new...more
The number of FCPA enforcement actions brought in recent years has declined. The SEC, for example, reports that in fiscal 2013 it brought 8 cases, compared to 10 in 2012 and 15 in 2011. Nevertheless, those who might be...more
In response to a recent joint enforcement action by the CFPB and Department of Justice alleging violations of the Equal Opportunity Credit Act, and its implementing regulation, Regulation B, the National Automobile Dealers...more
This issue of the Credit Crunch Digest focuses on new fines and criminal charges in Libor-related cases; the staggering potential costs of resolving lawsuits filed by regulators against the major banks; a settlement in the...more
This past March, Carl Nuss — a 75-year-old used car dealer from Birmingham, Alabama — received a letter from one of his customers, requesting that Mr. Nuss reduce the customer’s interest rate to six percent since the customer...more
In 2013, the U.S. Department of Justice (“DOJ”), Health and Human Services Office of Inspector General (“HHS-OIG”), and other federal and state agencies continued to aggressively prosecute health care fraud and related...more
Over the last two years, enforcement of the Foreign Corrupt Practices Act (“FCPA”) has remained a priority of the U.S. Department of Justice (“DOJ”) and Securities and Exchange Commission (“SEC”). That emphasis is likely to...more
I always say that the government does not enforce the laws in secret – they tell business what they plan to do and then they carry it out. The announcement of an enforcement initiative is always followed by a series of press...more
Gone are the days when everyone wondered whether FCPA enforcement was slowing down. The Justice Department and the SEC have answered that question with a resounding statement – “We are here to stay.”...more
What is the risk?
Third-party liability for contractors, resellers, agents and supply chain partners is an issue that continues to bedevil corporations who need or choose to use third parties. The headlines and DOJ/SEC...more
The insider trading trial of former SAC Capital official Matthew Martoma opened this week in Manhattan with jury selection. The SEC announced the resignation of George Canellos, Co-director of the Division of Enforcement....more
In this issue:
- Recent Trends and Patterns in FCPA Enforcement
- Foreign Bribery Criminal Prosecution under the FCPA
- Foreign Bribery Civil Actions Instituted by the Department of Justice under the...more
The new year — 2014 — will continue with aggressive FCPA enforcement, prosecutions of individuals (retrospective and prospective cases, with some interesting twists along the way. Each year is different in one way or...more
This year had the largest number of individual Foreign Corrupt Practices Act (FCPA) enforcement actions since 2010, the year of the Gun Sting case. Here are the highlights of FCPA related enforcement actions against...more
Insider trading remains a top priority for the Securities and Exchange Commission (SEC) and Department of Justice (DoJ). In fiscal year 2012, the SEC filed 58 enforcement actions against 131 individuals and entities and the...more
To continue a “tradition” on Corruption Crime and Compliance, I like to end the year with recognition of the “person of the year,” referring to the institution which has had the most impact in the enforcement and compliance...more
As the Justice Department has stepped up its pursuit of financial institutions, there has been a surge of civil fraud lawsuits brought by the government under FIRREA — the Financial Institutions Reform, Recovery, and...more
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