The Foreign Corrupt Practices Act Anti-Bribery

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.
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ENI Receives ISO 37001 Certification and ENI CEO Charged with Corruption

Today’s headline is inspired by two recent notices; the first is from a January 25 ENI Press Release crowing that “Eni is the first Italian company to receive that certification”. The second came from an article in the...more

Foreign Corrupt Practices Act 2016 Year-End Update

2016 was a record-setting year for Foreign Corrupt Practices Act (“FCPA”) enforcement, as both the U.S. Department of Justice (“DOJ”) and the U.S. Securities and Exchange Commission (“SEC”) recovered well over $2 billion in...more

Sapin II - France’s War on Corruption

In July 2015, Michel Sapin, the French Minister of Finance, summarized his proposals for a new French law prohibiting corruption and seeking “transparency in economic life”. That law, modeled after the U.S. Foreign Corrupt...more

Enforcement Trends: Anti-Corruption and the Foreign Corrupt Practices Act

How will the enforcement landscape change under a new administration? In this podcast, Colleen Conry, Alex Rene and Michael Casey of Ropes & Gray’s government enforcement practice in Washington, D.C., discuss the potential...more

Teva FCPA Enforcement Action-Part I

Just when you were thinking things could not get any bigger after the Odebrecht/Braskem Foreign Corrupt Practices Act (FCPA) enforcement action, the Department of Justice (DOJ) and Securities and Exchange Commission (SEC)...more

ISO 37001 – The Potential Impact of the New International Anti-Bribery Management System Standard

The International Organization for Standardization (“ISO”) recently published ISO 37001, the first international anti-bribery management system standard. ISO, a Swiss-based international organization, is well known for...more

Anti-bribery compliance in India: Both sword and shield

In recent years, both the United States Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) have stepped up their enforcement of the Foreign Corrupt Practices Act (FCPA), including to address...more

Embraer’s FCPA Deferred Prosecution Agreement and $205 Million Payment Demonstrate Need for Adequate Internal Controls

Brazilian aircraft manufacturer Embraer SA (“Embraer”) will pay the United States government $205 million to settle allegations that the company violated the Foreign Corrupt Practices Act (“FCPA”) by paying millions in bribes...more

White Collar Crime Law Enforcement in a Trump Justice Department - 8 Predictions

After a conventional presidential campaign, determining the policy priorities and direction of the incoming administration with respect to the Justice Department’s white collar law enforcement responsibilities can be a...more

Don’t Let Forced Labor and Bribery in Your Supply Chain Spoil the Holidays

The holiday retail season is an ideal time to check that forced labor and bribery—two top and interconnected supply-chain threats—do not undermine the success of your critical sales period. Not long ago, many in the...more

Top Ten International Anti-Corruption Developments for October 2016

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

ISO 37001: Answers to the 5 Questions We’ve Heard Most About the Standard

It’s been a month since ISO 37001 was published and there are some questions we have heard percolating in the compliance world about what this means. These are the questions we’ve been hearing the most...more

A Cautionary Illustration of the Need for Accounting and Compliance Reviews

Embraer SA, Brazil's flagship aerospace manufacturer and a worldwide competitor across various aviation markets, experienced first-hand the scope and reach of the Foreign Corrupt Practices Act (FCPA). Embraer agreed to pay...more

ISO 37001: Why Your Anti-Corruption Policy Needs to Go Global

Ten years ago the standard anticorruption policy was nearly exclusively FCPA-focused. DOJ and SEC enforcement actions were the primary, if not the only, concern for corporate executives and board members. The UK Bribery Act...more

International Standards Organization issues certification standard for anti-bribery compliance systems

On October 15, 2016, the International Standards Organization Technical Committee ISO/PC 278 issued ISO 37001 titled, "Anti-bribery management systems - Requirements with guidance for use." ISO 37001(the Standard) "specifies...more

FCPA Enforcement Action Highlights Risks for the Financial Services Industry and Individual Executives

New York-based hedge fund Och-Ziff Capital Management Group (the “Hedge Fund”) agreed to pay approximately $412 million to resolve charges brought by the U.S. Securities and Exchange Commission (“SEC”) and Department of...more

A New Tool for Anti-Bribery Compliance Program: ISO 37001

Recently, the International Organization for Standardization (ISO) adopted a new set of standards, designated as ISO 37001, to assist organizations in their ongoing fight against bribery. As a result of recent increases in...more

Tribute to Star Trek and Anti-Corruption Compliance Programs

September 8th is the 50th anniversary of the premier episode of the most iconic science fiction related television show during my lifetime – Star Trek. As most of you know, I am a self-confessed uber-trekkie and I can still...more

Australian Companies Face Greater Scrutiny With New Foreign Bribery Investigations Team

On 5 September 2016, the Commonwealth Government announced the establishment of a Perth-based specialised fraud and anti-corruption team that will focus on foreign bribery investigations. Justice Minister Michael Keenan has...more

Hallmark 4- Risk Assessments

One cannot really say enough about risk assessments in the context of anti-corruption programs. Since at least 1999 the DOJ has said that risk assessments that measure the likelihood and severity of possible Foreign Corrupt...more

"China and the Foreign Corrupt Practices Act"

Recent U.S. Department of Justice (DOJ) policies on corporate crime prosecutions, coupled with the Chinese government’s robust anti-corruption campaign, are proving challenging for U.S. corporations with business operations...more

U.S. Targets Private Equity Funds for FCPA Scrutiny

The private equity industry is facing increased scrutiny by the U.S. Government for potential violations of the Foreign Corrupt Practices Act (“FCPA”). The Securities and Exchange Commission (“SEC”) has created a new private...more

Corporate Investigations and White Collar Defense - June 2016

Eye on the Supreme Court—Corruption and Fraud Edition - Why it matters: This session, the Supreme Court has undertaken the review of numerous cases that raise thorny issues arising in the white collar context. In our...more

France Considers New Anti-Corruption Authority

France has introduced a draft bill which proposes to establish a new anti-corruption authority, which will have the power to impose administrative sanctions and conduct US-style monitoring of companies’ anti-bribery...more

ISO 37001: A New Measuring Stick for Corporate Compliance Programs

The International Organization for Standardization is developing a certifiable international standard for “anti-bribery management systems” that could influence how the US Department of Justice, US Securities and Exchange...more

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