FCPA Survival Guide - Step 8 - Investing in Compliance
Episode 328 -- Sanctions Enforcement Risks and Redlines
FCPA Survival Guide: Step 3 - Extensive Remediation
Episode 324 -- Third-Party Risks and Sanctions Compliance
Compliance Tip of the Day – Compliance Lessons from the Albemarle FCPA Enforcement Action
FCPA Survival Guide: Step 1 - Self-Disclosure
All Things Investigations: Compliance Lessons from Gunvor and Trafigura Enforcement Actions
Corruption, Crime & Compliance: Deep Dive into The Trafigura FCPA Settlement
Episode 317 -- A Deep Dive into the Trafigura FCPA Settlement
What's Going on with FCPA?
Episode 316 -- DOJ Announces New Whistleblower Policy
Compliance into The Weeds: Trafigura FCPA Enforcement Action
Corruption, Crime & Compliance: Deep Dive into The Gunvor FCPA Settlement
Episode 314 -- A Deep Dive into Gunvor's FCPA Settlement
Corruption, Crime & Compliance: DOJ’s Shifting Approach to Recidivism and Self-Disclosure
Episode 311 -- Tom Fox on FCPA Enforcement: Self Disclosure and Recidivism
Episode 307 -- Sanctions Enforcement Review and Predictions for 2024
Episode 305 -- Deep Dive into SAP FCPA Settlement
Compliance Into The Weeds: The SAP Foreign Corrupt Practices Act Enforcement Action
Episode 300 -- Deep Dive into DOJ FCPA Settlement with Two U.K. Reinsurance Companies for Bribery in Ecuador
While FCPA enforcement against companies has been relatively quiet this year, despite a strong beginning to the year — the SAP case for $220 million; and the Gunvor case for $661 million — DOJ has been pushing a number of...more
I recently spoke with the Foreign Corrupt Practices Act (FCPA) Handbook authors Robert Tarun and Peter Tomczak from Baker McKenzie for a two-part podcast episode. The depth of knowledge and experience in white-collar crime,...more
In this new era of aggressive sanctions enforcement, companies have to understand the red lines that define where criminal and civil enforcement risk increase. In contrast to the history of FCPA enforcement, DOJ and OFAC...more
The government had another busy year in 2023, investigating and prosecuting healthcare fraud cases on multiple fronts. Contending with the enormous healthcare crises of the now-concluded COVID-19 pandemic and the ongoing...more
Recent bribery and corruption enforcement efforts by the US Department of Justice (DOJ) and US Securities and Exchange Commission (SEC), combined with new legislative and policy initiatives, including last December’s passage...more
We are thrilled to introduce the inaugural issue of our quarterly White Collar newsletter, a dedicated resource from Benesch’s White Collar, Government Investigations & Regulatory Compliance Practice Group. Each issue...more
In March 2024, the Department of Justice (DOJ) announced the resolution of a Foreign Corrupt Practices Act (FCPA) enforcement action involving the Swiss trading firm G Trafigura Beheer B.V. (Trafigura), an international...more
Hosted by American Conference Institute, the 14th Annual Summit on Anti-Corruption, Integrity & ESG returns to Brazil for another groundbreaking year to discuss the current high-stakes dilemmas impacting your organization....more
Both the Organisation for Economic Co-operation and Development (OECD) and the U.S. Strategy on Countering Corruption recognize that the news media plays a vital role in the detection of bribery and other acts of corruption...more
This is the seventh in our 2024 Year in Preview series examining important trends in white collar law and investigations in the coming year. We will be posting further installments in the series throughout the next several...more
The Department of Justice’s blockbuster FCPA settlement with Gunvor restores the credibility of DOJ’s pronouncements of DOJ’s commitment to aggressive FCPA enforcement. While I have questioned DOJ’s commitment to its...more
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
We continue our exploration of the resolution of the FCPA enforcement action involving the Swiss trading firm Gunvor S.A. The enforcement action came in with a $661 million penalty against the company, which has pleaded...more
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
In this special episode of Corruption, Crime, and Compliance, Michael Volkov joins colleague and long-time friend Tom Fox as they delve into the intricacies of recent FCPA enforcement actions, shedding light on the evolving...more
When it comes to FCPA enforcement, the Justice Department’s global focus for many years was on Asian countries, and in particular, China. This trend, however, has continued, but in the past few years, DOJ has brought a...more
Over the past 15 months, the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) have made clear, through three Foreign Corrupt Practices Act (FCPA) enforcement actions and speeches, their priorities in...more
If companies operated with perfect governance mechanisms and controls, they would all be ready for the coming sanctions enforcement storm. However, that is not the corporate reality. Even after several companies are the...more
There are some things you learn best in calm, and some in storm. Willa Cather I know I sound like a broken record. The Justice Department’s white collar criminal enforcement has been trending down over the last few...more
Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, our Foreign Corrupt Practices Act (FCPA) Year In Review provides quick, visual representations of key trends in FCPA enforcement over...more
Publicly announced Foreign Corrupt Practices Act (FCPA) enforcement activity in 2023 did not return to the levels seen a few years ago, as indicated by both the total number of cases against corporate and individual...more
ACI’s Mexico Summit on Anti-Corruption & Compliance Programs returns on March 13-14, 2024 in Mexico City! Given the uncertainty with the looming Presidential election, as well as increased U.S. enforcement focus on Mexico...more
This week we are taking a deep dive into the SAP Foreign Corrupt Practices Act (FCPA) enforcement action. In it, SAP agreed to pay the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) approximately...more