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Foreign Corrupt Practices Act (FCPA) Corporate Monitoring

StoneTurn

Meeting DOJ and SEC Post-Settlement Obligations: A Practical Guide

StoneTurn on

No Longer Just a Matter of Paying the Fine and Moving On. Corporate settlement agreements used to be straightforward—pay the penalty and move on. Now, these resolutions rival complex business transactions, including...more

Thomas Fox - Compliance Evangelist

FCPA Compliance Report - James Koukios on the Monaco Speech

In this episode of the FCPA Compliance Report, I am joined by fan-favourite James Koukios, a partner at Morrison and Foerster, and we take a deep dive into the Lisa Monaco speech from October and related remarks from other...more

Morgan Lewis

DOJ Discusses Enforcement, Reiterates Biden-Harris Anti-Corruption Commitment at ACI FCPA Conference

Morgan Lewis on

This LawFlash summarizes key takeaways from the American Conference Institute’s (ACI’s) 38th International Conference on the Foreign Corrupt Practices Act (FCPA), where top government officials offered insight and...more

Katten Muchin Rosenman LLP

DOJ Signals Increased Use of Corporate Monitors

On October 28, 2021, Deputy Attorney General Lisa Monaco announced revised Department of Justice (DOJ) guidance on corporate monitors. Going forward, prosecutors are free to require the imposition of a corporate monitor when...more

The Volkov Law Group

Deputy AG Lisa Monaco Suggests Major Changes to the DOJ’s Corporate Enforcement Efforts

The Volkov Law Group on

On October 28, 2021, U.S. Deputy Attorney General Lisa O. Monaco—a veteran of government service in previous Administrations and a champion of corporate accountability—announced several significant changes to current...more

Latham & Watkins LLP

Senior US DOJ Official Sets Forth New Priorities for Pursuing Corporate Crime

Latham & Watkins LLP on

The priorities will impact non-US companies who may face a US DOJ with a renewed emphasis on combating corporate crime. In a recent speech that has garnered significant attention, the Deputy Attorney General of the...more

American Conference Institute (ACI)

[Webinar] FCPA Data Analytics, The Board and Senior Management - May 18th, 1:00 pm - 2:00 pm EDT

5 Things to Know for Securing Buy-In and Budgets for Data-Driven Compliance, Monitoring and Investigations... During this one-hour webinar, you will gain practical takeaways on: - What to anticipate: Recent examples of...more

The Volkov Law Group

The Curious Absence of Corporate Monitors

The Volkov Law Group on

In 2020, the Justice Department did not insist on the appointment of any independent compliance monitors.  The year before, in 2019, DOJ insisted on the appointment of three independent corporate monitors – MTS...more

Thomas Fox - Compliance Evangelist

It’s The Great Pumpkin Charlie Brown - Lessons in Process Validation Through Continuous Monitoring

Halloween is almost upon us and we celebrate the greatest Halloween cartoon in the history of the world, ever, “It’s the Great Pumpkin, Charlie Brown”, which premiered in 1966. As usual, the story revolves around the Peanuts...more

Thomas Fox - Compliance Evangelist

HorrorFest 2020 Celebration: The Revenge of Frankenstein and the J&F FCPA Resolution

In this third edition of October HorrorFest 2020 celebration we consider the first Hammer film sequel (and second in the series) – The Revenge of Frankenstein which was released in 1958. It begins as the Curse of Frankenstein...more

Thomas Fox - Compliance Evangelist

Talent Mix: Maximizing Your Program’s Reach with Diverse Skillsets

Ed. Note-We welcome back Troy McAlister with another guest post. Troy brings 20 years of experience at both public and private companies, in public accounting and in a variety of industries. Troy has experience in...more

Thomas Fox - Compliance Evangelist

FCPA Compliance Report-Episode 511 – Jay Rosen on the Lack of Monitorship

In this special five-part podcast series, I take a deep dive into the recent Herbalife FCPA Resolution. Over the next 5 podcast Mike Volkov, Jay Rosen, Matt Kelly, Jonathan Marks and Jonathan Armstrong will all bring their...more

Thomas Fox - Compliance Evangelist

2020 Update Review: Part 2 – Data, Continuous Monitoring and Continuous Improvement

Late Monday, the Department of Justice (DOJ), without fanfare, released an update to its 2019 Evaluation of Corporate Compliance Programs, the 2019 Guidance. For simplicity this new document will be called the 2020 Update. ...more

Vinson & Elkins LLP

Monitoring Corporate Monitors: DOJ Publishes List of Compliance Monitors, Improving Transparency and Accountability in the...

Vinson & Elkins LLP on

On April 14, 2020, for the first time, the Department of Justice (“DOJ”) published a list identifying all corporate monitors actively engaged by companies as a part of criminal resolutions with the Criminal Division’s Fraud...more

Kilpatrick

Ending the Decade on a High: U.S. Government’s 2019 FCPA Enforcement Highlights

Kilpatrick on

The U.S. Government’s 2019 FCPA enforcement efforts led to new milestones; further cooperation with international authorities; and continued use of independent corporate monitors.  The following are key takeaways of these...more

Society of Corporate Compliance and Ethics...

[Event] March Basic Compliance & Ethics Academy - March 2nd - 5th, San Diego, CA

Our Basic Academies are ideal for professionals with some compliance knowledge and experience who are ready to support, enhance and manage a comprehensive compliance program. They are taught by compliance professionals,...more

Skadden, Arps, Slate, Meagher & Flom LLP

Ericsson Agrees To Pay Over USD $1 Billion To Settle FCPA Charges

On December 6, 2019, Telefonaktiebolaget LM Ericsson (Ericsson or the Company), resolved long-running investigations by the U.S. Department of Justice (DOJ) and the U.S. Securities and Exchange Commission (SEC) into the...more

ArentFox Schiff

Investigations Newsletter: Ten Former NFL Players Charged with Defrauding League's Health Care Benefits Plan

ArentFox Schiff on

Ten Former NFL Players Charged with Defrauding League's Health Care Benefits Plan - On December 12, the DOJ unsealed two indictments charging ten retired NFL players with defrauding the league's retiree health care...more

Thomas Fox - Compliance Evangelist

Billion Dollar Baby: Ericsson FCPA Enforcement Action – Part 1: Introduction

Last week the Justice Department (DOJ) announced a resolution of the long stand Foreign Corrupt Practices Act (FCPA) enforcement action involving Telefonaktiebolaget LM Ericsson (Ericsson), a multinational networking and...more

The Volkov Law Group

Episode 119 -- The Ericsson FCPA Settlement

The Volkov Law Group on

The Sweden-based telecommunications company, Ericsson, agreed to a pay a total of $1 billion (yes, billion with a “B”) for FCPA violations. Ericsson entered into settlement agreements with DOJ and the SEC. Ericsson agreed to...more

Thomas Fox - Compliance Evangelist

Casebook of Sherlock Holmes: The Lion’s Mane and Risk-Based Monitoring

By using risk-based monitoring, you can begin to see things in “almost real-time, time-based trends of real data that you can then jump on and try to make adjustments before things get really wacky.” The implications to the...more

Thomas Fox - Compliance Evangelist

Walmart FCPA Enforcement Action: Part 1 – Introduction

The big one finally is resolved. The long-awaited Walmart Inc. (Walmart) Foreign Corrupt Practices Act (FCPA) enforcement action was announced yesterday. This massive case came in with multiple documents, a long list of...more

A&O Shearman

DOJ Revises FCPA Corporate Enforcement Policy

A&O Shearman on

On March 8, 2019, the Department of Justice (“DOJ”) released a revised version of its FCPA Corporate Enforcement Policy (the “Policy”), which provides enforcement and practice guidance to DOJ prosecutors and was formally...more

Eversheds Sutherland (US) LLP

Russian telecom giant to pay record-breaking penalty for FCPA violations

On March 6, 2019, Mobile TeleSystems PJSC (MTS) consented to pay an $850 million sanction—the largest Foreign Corrupt Practices Act (FCPA) criminal penalty ever paid to the United States—and to a three-year monitorship to...more

Thomas Fox - Compliance Evangelist

MTS FCPA Settlement and Karimova Indictment: Part I-Introduction

In a stunning resolution to one of the longest running bribery, corruption and money-laundering sagas on the international stage, the Department of Justice (DOJ) and Securities Exchange Commission (SEC) both announced...more

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