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Foreign Corrupt Practices Act (FCPA) Corporate Executives

Ogletree, Deakins, Nash, Smoak & Stewart,...

Compelled Interviews Admissible in Criminal Prosecution Against Former Company President and Its General Counsel

A New Jersey federal court has ruled that a company’s self-disclosure of potential Foreign Corrupt Practices Act (FCPA) violations did not render the company a state actor, allowing evidence obtained by its internal...more

Wilson Sonsini Goodrich & Rosati

In the Year of the Rabbit, the DOJ Dangles More Carrots to Incentivize Self-Disclosure and Cooperation

Whenever a company detects criminal misconduct, it is faced with the difficult decision of whether to self-disclose the misconduct to the federal government. In an attempt to help nudge companies towards cooperation, the U.S....more

NAVEX

3 Ways to Apply New DOJ Guidance to Antitrust Compliance

NAVEX on

The Justice Department gave compliance officers a significant piece of guidance in June with its latest update to the evaluation of corporate compliance programs. The guidance begs the fundamental question: Is the compliance...more

Thomas Fox - Compliance Evangelist

Consistency as a Compliance Best Practice

I recently had the opportunity to visit with Asha Palmer, Convercent Chief Ethics and Compliance Officer (CECO) and Executive Vice President (EVP) of CONVERGE and Rex Homme, Partner at StoneTurn to consider some of the...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - December 2019

IN THIS ISSUE • Anticorruption Developments • Export Control Sanctions and Customs Enforcement • Export Control and Sanctions Developments • Global Investigations Resources • Writing and Speaking Engagements ...more

Thomas Fox - Compliance Evangelist

Executives Acting in Bad Faith and the Role of the Board

A piece by Dick Cassin in the FCPA Blog had some very stark language. He quoted from the Telefonaktiebolaget LM Ericsson (Ericsson) 6-K filing for the following, “While the Company had a compliance program and a supporting...more

Society of Corporate Compliance and Ethics...

Alstom SA executive found guilty of Foreign Corrupt Practices Act violations

CEP Magazine (January 2020) - After years of appeals and a two-week trial, a jury found former Alstom SA executive Lawrence Hoskins guilty of six counts of violating the Foreign Corrupt Practices Act (FCPA), three counts...more

McDermott Will & Emery

Assistant AG Provides Clarity on FCPA Self-Disclosure Credit

McDermott Will & Emery on

Assistant Attorney General Brian Benczkowski’s remarks provide important guidance for management and boards, and underscore the US Department of Justice’s commitment to prosecuting individuals for corporate misconduct....more

BCLP

In announcing changes to individual accountability policy, DOJ reaffirms that cooperating companies must name responsible...

BCLP on

On November 29, 2018, Deputy Attorney General Rod Rosenstein announced changes to the Department of Justice’s policy concerning individual accountability in corporate cases, stating that “pursuing individuals responsible for...more

Eversheds Sutherland (US) LLP

US Department of Justice relaxes Yates Memorandum’s requirements for earning cooperation credit

On November 29, 2018, the US Department of Justice (DOJ) modified prior guidance on individual liability for corporate misconduct by affording federal prosecutors discretion to focus on “individuals who play significant roles...more

Thomas Fox - Compliance Evangelist

FCPA Compliance Report-Episode 334, Lauren Briggerman

In this episode, I visit with Lauren Briggerman, a member at the firm of Miller & Chevalier. She discusses the latest edition of the firm newsletter, Executives at Risk: Navigating Individual Exposure in Government...more

Dechert LLP

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

Dechert LLP on

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

The Volkov Law Group

For An Effective Ethics and Compliance Program — First, Train Your Board and Senior Executives

The Volkov Law Group on

Compliance professionals are familiar with the phrase “tone at the top,” but what exactly does it mean? Unlike other compliance program components, it cannot be easily formalized and implemented in a policy or procedure....more

Thomas Fox - Compliance Evangelist

Hallmark 1 – Commitment from Senior Management and a Clearly Articulated Policy Against Corruption

Over the next two weeks I will be revisiting the Ten Hallmarks of an Effective Compliance program, as laid out in the 2012 A Resource Guide to the U.S. Foreign Corrupt Practices Act ( FCPA Guidance) authored by the Criminal...more

The Volkov Law Group

Train Your Board and C-Suite Now – The Under-Education of Corporate Leadership

The Volkov Law Group on

The next time we read about a train wreck of corporate malfeasance – be it in the anti-corruption, money laundering, financial reporting or any other space you can think of – please do not shrug your shoulders and shake your...more

Thomas Fox - Compliance Evangelist

Battle of the Somme Week – Part III: Lessons from Brexit

There have been a plethora of new books about the Battle of the Somme. Daniel Todman reviewed several in an article for the Financial Times (FT), entitled “Stories of the Somme”. One of the books reviewed, Breakdown: The...more

The Volkov Law Group

Dissecting a Bribery Violation: Two Important Questions to Answer

The Volkov Law Group on

In the wreckage of a corporate FCPA enforcement action, a company has to answer two important questions. First, how did the conduct occur without senior executives and the Board learning or suspecting that such conduct...more

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