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
Russia - Former Special Agent in Charge of the FBI New York Counterintelligence Division Charged with Violating U.S. Sanctions on Russia (DOJ) Those involved. Charles McGonigal, former Special Agent in Charge of the FBI...more
On 24 May 2022, Glencore International AG announced a series of coordinated resolutions with various international enforcements agencies including the Department of Justice (”DOJ”), the Commodity Futures Trading Commission...more
False Claims Act Legal Developments - First Circuit Upholds Whistleblower Retaliation Verdict - On December 9, 2020, the US Court of Appeals for the First Circuit held as a matter of first impression that “the...more
On July 3, 2020, the U.S. Department of Justice (DOJ) and U.S. Securities and Exchange Commission (SEC) jointly released the second edition of the “Resource Guide to the U.S. Foreign Corrupt Practices Act,” which was...more
...Think your company and its employees are beyond the reach of U.S. authorities? Maybe you don’t have U.S. operations there, or your company isn’t publicly traded on a U.S. stock exchange. Perhaps you don’t directly sell or...more
On Friday, November 8, 2019, a jury convicted British citizen Lawrence Hoskins of one count of conspiracy to violate the Foreign Corrupt Practices Act (FCPA), six counts of violating the FCPA, one count of conspiracy to...more
This issue of Skadden’s semiannual Cross-Border Investigations Update takes a close look at recent cases, regulatory activity and other key developments, including a review of the first year of GDPR enforcement, analysis of...more
Despite the fact that the Foreign Corrupt Practices Act has been in force for decades there is relatively little case law interpreting its provisions. A great deal of the existing interpretation of the Act stems from...more
On August 24, 2018, the US Court of Appeals for the Second Circuit held in United States v. Hoskins that a foreign national who does not otherwise fall under “the categories of persons directly covered” by the FCPA cannot be...more
On August 27, 2018, a three-judge panel of the Second Circuit limited the extraterritorial application of the Foreign Corrupt Practices Act (“FCPA”), holding the statute does not apply to foreign nationals who commit crimes...more
Over the years, the Foreign Corrupt Practices Act of 1977 (FCPA) has expanded beyond U.S. issuers and domestic concerns to cover foreign companies and foreign individuals. The Department of Justice and the U.S. Securities and...more
On August 24, 2018, the United States Court of Appeals for the Second Circuit issued a significant ruling regarding the reach of the U.S. Foreign Corrupt Practices Act (FCPA) over foreign companies and individuals in United...more
Introduction - Recent actions involving conduct in Asia highlight the increasing complexity and global coordination of anti-corruption efforts. Though large settlements with Odebrecht and Braskem in 2016 have kept the...more
ANTICORRUPTION DEVELOPMENTS – Global Compliance Overhaul for SAP as DOJ and SEC Investigate Payments Allegedly Related to South African Government Contracts – On October 26, 2017, German software company SAP SE...more
According to a memo circulating amongst Republican-party leaders as of February 13th, Republicans in the House of Representatives are planning to propose a significant curtailment of the U.S. Securities and Exchange...more
ANTICORRUPTION DEVELOPMENTS – DOJ Issues First-Ever Declinations Requiring Disgorgement of Profits to Resolve FCPA Violations - On September 29, 2016, the Department of Justice (DOJ) for the first time announced...more
Welcome to the July 2014 edition of Red Notice, a publication of Akin Gump Strauss Hauer & Feld LLP. This month on the anticorruption front, two Noble Corporation executives settle with the U.S. Securities and Exchange...more
Last week I was in Miami and part of the discussion was over the Esquenazi appeal and Direct Access Partners (DAP) enforcement actions; both based upon violations of the Foreign Corrupt Practices Act (FCPA). In the DAP...more
One of my favorite Seinfeld episodes is “The Opposite” when George decides to do the opposite of his natural inclination, and lo and behold, his life suddenly approves....more
On May 29, French oil and gas company, Total SA, agreed to pay $398 million to settle US civil and criminal allegations that it paid bribes to win oil and gas contracts in Iran in violation of the Foreign Corrupt Practices...more