The Foreign Corrupt Practices Act

The Foreign Corrupt Practices Act is a United States Federal law enacted in 1974 to create transparency and prevent bribery for U.S.-based corporations conducting business overseas.
News & Analysis as of

Corporate Compliance Programs: US and UK Perspectives

In today’s regulatory environment, companies face mounting pressure from law enforcement agencies to maintain robust compliance programs to deter and detect misconduct by employees, third-party vendors and business partners....more

LRN Compliance Program Effectiveness Report: Part III

This week I have been considering the LRN Corporation’s 2016 Ethics and Compliance Program Effectiveness Report (LRN Report) by outlining some of its general findings. Today, I want to conclude by using the Report as a road...more

LRN Compliance Program Effectiveness Report: Part II

Yesterday I began a series on the LRN Corporation’s (LRN) 2016 Ethics and Compliance Program Effectiveness Report (Report) by outlining some of its general findings. Today, I want to focus on its detailed findings as it...more

Doing Business in Cuba Under the FCPA

I want to consider the impending opening of Cuba to US business, what you can do now and what you must wait for until the embargo is lifted; all from the perspective of compliance with the Foreign Corrupt Practices Act...more

Understanding the New DOJ Guidance: Part 1 – Tone at the Top

In February, the Department of Justice’s Fraud Section offered a new perspective on what the government expects in a compliance program in the form of a series of questions that companies should be prepared to answer about...more

Justice Department Reveals How It Evaluates Corporate Compliance Programs

The U.S. Department of Justice (DOJ) Fraud Section recently published its "Evaluation of Corporate Compliance Programs" that lists 1) the topics it explores and 2) the questions it asks when it assesses the effectiveness of a...more

Rules of the (International) Road

Going international is a complicated undertaking. Your specific situation and concerns will determine the steps required. The following outlines, very generally, some issues you must consider as you contemplate international...more

Sapin II Law: The new French legal framework for the fight against corruption

Law no. 2016-1691 on transparency, fighting corruption and modernising economic life was published in the Official Gazette on 10 December 2016. Known as the Sapin II Law, its main objective is to set up a genuine...more

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

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

Deep Dive Due Diligence: Part V – Level III Due Diligence as a Board Tool

Today, I conclude my exploration of Level III, deep dive due diligence, by discussing how a this should be considered as a best practices tool by a Board of Directors in a broader sense. I am joined in this exploration by...more

New Guidance Document: How DOJ Evaluates Corporate Compliance Programs

The U.S. Department of Justice (DOJ) has issued compliance guidance for corporations that outlines how the Fraud Section will likely evaluate the corporate compliance program of a company under criminal investigation....more

Updated Status of the DOJ FCPA Pilot Program

The FCPA Pilot Program was introduced on April 5, 2016 as a one year experiment that sought to ‘motivate companies to voluntarily self-disclose FCPA-related misconduct, fully cooperate with the Fraud Section and …remediate...more

DOJ Announces Temporary Extension of FCPA “Pilot Program”

The U.S. Department of Justice (DOJ) announced on March 10, 2017 that it will temporarily extend the “Pilot Program” applicable to offenses under the U.S. Foreign Corrupt Practices Act (FCPA). Previously set to expire on...more

DOJ’s Recent Guidance on Compliance Programs

In assessing potential sanctions against corporations, prosecutors must decide whether and how to exercise their discretion when evaluating penalties to impose upon a company whose employees engaged in wrongdoing despite the...more

Deep Dive Due Diligence: Part IV – Level III Due Diligence for 3rd Parties

Today, I continue my exploration of Level III, deep dive due diligence, by discussing how this should be considered for third parties. I am joined this week by Candice Tal, founder and Chief Executive Officer (CEO) of...more

DOJ’s Compliance Program Evaluation Guidance

The Justice Department’s recent guidance on compliance programs, consisting of 110 separate questions, organized around specific compliance topics, has raised a number of interesting procedural and substantive issues....more

The DOJ Expects “Third-Party Management” from Compliance Programs

2016 was a banner year for global anti-corruption enforcement: the U.S. government set records in terms of both the number of FCPA actions brought and the total dollar amount of related fines. Meanwhile, governments from...more

Uptick In Coordinated U.S.-Brazil Anti-Corruption Enforcement

As companies expand across borders and invest more heavily abroad, foreign enforcement authorities are following the example set by the U.S. Department of Justice and the U.S. Securities and Exchange Commission in directing...more

Investor Suits Follow in the Wake of Western Union Settlement of Money Laundering and Fraud Claims

On January 19, 2017, the Western Union Company (“Western Union” or the “Company”) entered into a deferred prosecution agreement (“DPA”) with the Department of Justice (“DOJ”), in which Western Union admitted to willful...more

DOJ Extends FCPA Pilot Program

On Friday, March 10, Kenneth Blanco, the acting assistant attorney general for the Department of Justice’s Criminal Division, announced that the FCPA Pilot Program would not expire on April 5, 2017, as originally scheduled....more

DOJ Defines Compliance

In the span of the last 18 months, the topic of corporate compliance programs has gotten considerable attention from the Department of Justice (“DOJ”) and now finally, DOJ has published significant details about how it is...more

DOJ Pilot Program Will Continue…For Now

On March 10, a U.S. Justice Department official announced that agency will continue its one-year Pilot Program, which was introduced by DOJ’s Fraud Section and set to expire on April 5 of this year. As we described in an...more

Day 10 of One Month to Operationalizing Your Compliance Program-the Role of Payroll in Compliance  [Video]

The role of global payroll in FCPA compliance is not often considered in operationalizing your compliance program, yet the monies to fund bribes in violation of the FCPA must come from somewhere. Unfortunately, one of those...more

DOJ Announces Extension of FCPA Pilot Program

The US Department of Justice plans to extend its FCPA Pilot Program, an initiative developed to encourage companies to self-report bribery violations and provide extensive cooperation in exchange for reduced penalties,...more

The SEC Speaks 2017: Division of Enforcement Highlights

At the SEC Speaks 2017 conference, held in Washington, D.C. from February 24-25, 2017, senior Securities and Exchange Commission (“SEC”) officials shared their observations about the SEC’s Division of Enforcement’s...more

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Cybersecurity

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