A Resource Guide to the Foreign Corrupt Practices Act is a joint compilation between the United States Department of Justice and the United States Securities and Exchange Commission detailing... more +
A Resource Guide to the Foreign Corrupt Practices Act is a joint compilation between the United States Department of Justice and the United States Securities and Exchange Commission detailing important aspects, provisions and enforcement procedures of the Foreign Corrupt Practices Act.
Charles Duross, deputy chief of the Department of Justice’s (DOJ) Criminal Division, Fraud Section, offered white collar crime practitioners rare insight into the DOJ’s and the Security and Exchange Commission’s (SEC)...more
Timing is everything. Woody Allen said it best – 80 percent of life is just showing up. Unless you are the Chamber of Commerce. Talk about bad timing and sour grapes....more
More than 35 years after becoming law, the Criminal Division of the United States Department of Justice and the Enforcement Division of the Securities and Exchange Commission released their long-awaited guidance on the...more
As referenced in several recent articles in the Global Connection, on November 18, 2012, the Department of Justice (DOJ) and Securities Exchange Commission (SEC) issued a written guide in regard to compliance of the Foreign...more
Anti-corruption issues continue to present significant risks in acquisition and investment transactions because regulators continue robust enforcement in this area and emerging markets often present the greatest economic...more
Originally published in Swampfox - January 22, 2013. In November 2012 the Department of Justice and the Securities and Exchange Commission issued a 120-page “resource guide” to the U.S. Foreign Corrupt Practices Act. ...more
On December 17, 2012, the Securities and Exchange Commission (“SEC”) announced a settlement under the U.S. Foreign Corrupt Practices Act (“FCPA”) with Allianz SE (“Allianz”), the insurance company based in Germany, resulting...more
One of my favorite “Seinfeld” episodes is when Jerry and George go to NBC to pitch their new television show which is about “nothing.” There are some parallels to this posting. FCPA settlements have dwindled during 2012....more
This Part III is the final installment of my review of the Eli Lilly and Company (Lilly) FCPA enforcement action brought by the Securities and Exchange Commission (SEC). In this Part III, I will review the FCPA issues that...more
In Parts II and III of my review of the Eli Lilly and Company (Lilly) Foreign Corrupt Practices Act (FCPA) enforcement action brought by the Securities and Exchange Commission (SEC), I will discuss some the processes and...more
On November 14, 2012, the Criminal Division of the United States Department of Justice ("DOJ") and the Enforcement Division of the United States Security and Exchange Commission ("SEC") issued "A Resource Guide to the U.S....more
The United States Department of Justice ("DOJ") and the Securities and Exchange Commission ("SEC") recently released the long awaited joint guidance on the Foreign Corrupt Practices Act ("FCPA") in the form of a 130 page...more
On November 14, 2012, the SEC and the DOJ released their long-awaited Resource Guide to the Foreign Corrupt Practices Act, which can be found here. The Resource Guide consolidates and summarizes the government’s previously...more
The FCPA Guidance includes some important reminders for compliance practitioners. Most significantly, DOJ and SEC want companies to reinvigorate their risk assessment process. ...more
The FCPA Guidance is an advertisement for the government’s voluntary disclosure program. DOJ and SEC repeat their message – if you voluntarily disclose, you will get a benefit. As demonstrated in the declinations, companies...more
On November 8, 2012, we opined in the Global Connection as to what to expect from the anticipated Department of Justice (DOJ) and Securities Exchange Commission (SEC) guidance in regard to the Foreign Corrupt Practices Act...more
I am really enjoying reading and re-reading the FCPA Guidance. It is a fascinating document, well written and chock full of salient points, messages, explicit and implicit. For me, the most important issues are those...more
Much has been said about what is missing from the new FCPA Resource Guide (the Guide) published by the U.S. Department of Justice (DOJ) and the Securities and Exchange Commission (SEC). Here, we consider instead the areas in...more
Notwithstanding our overall approval of the FCPA Resource Guide (the Guide) issued by the Department of Justice (DOJ) and Securities & Exchange Commission (SEC) earlier this month, we are certainly not above a bit of...more
The FCPA Guidance could not have been clearer; it could not have offered more incentives and carrots to the business community. If you adopt and implement an “effective” compliance program, you will receive significant...more
Originally published in The FCPA Report on November 28, 2012. On November 14, 2012, the DOJ and SEC jointly published “A Resource Guide to the U.S. Foreign Corrupt Practices Act” (Guidance), their long-awaited and...more
On November 14, 2012, the Department of Justice (DOJ) and the U.S. Securities and Exchange Commission (SEC) jointly released A Resource Guide to the U.S. Foreign Corrupt Practices Act (the “Guide”). The Guide is intended to...more
The US Chamber of Commerce “praised” the FCPA Guidance. The Chamber did not get what it wanted but it had to recognize that the FCPA Guidance was helpful for businesses. The FPCA Guidance provides important information for...more
On November 14, 2012, the Criminal Division of the U.S. Department of Justice (DOJ) and the Enforcement Division of the U.S. Securities and Exchange Commission (SEC) released their much-anticipated FCPA guidance, entitled “A...more
Compliance professionals need to thank DOJ and SEC for the FCPA Guidance discussion on corporate compliance. DOJ and SEC provide important suggestions for improving compliance but they do so while reaffirming several...more
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