The Foreign Corrupt Practices Act Dept. of Justice

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.
News & Analysis as of

The Evolution of Compliance: Structural Changes Which Led to Compliance 2.0

If there was one theme from Compliance Week 2016 it was the continued evolution of the Chief Compliance Officer (CCO) role and the compliance profession. Long gone are the days when someone is sent over from a legal...more

CCO Independence, Authority and Resources as Indicia of an Effective Compliance Program

At the Opening Session of Compliance Week 2016, Stephen L. Cohen, Associate Director of Enforcement, Securities and Exchange Commission (SEC) and Andrew Weissmann, Chief of the Department of Justice (DOJ) Criminal Division’s...more

Global Standardization of Enforcement

Maybe I am a Luddite; maybe I just do not understand the new world and the impact of globalization. New ideas do not scare me, like others we know. New ideas present real opportunities for progress and innovation....more

The SEC, CCOs and Compliance Programs

Compliance programs, Chief Compliance Officers and liability have been the subject of a great deal of debate in recent months. Members of the Commission, for example, debated charging decisions regarding CCOs last year in...more

Swiss Extradite Final FIFA Official Arrested in May 2015 Sweep

On May 18, former President of the Nicaraguan Football Federal Julio Rocha was extradited from Switzerland to the United States. He was the final FIFA official to be extradited following the arrests made in Zurich in May...more

Joe Howell on the PCAOB, Audits and Compliance – Part IV

This week I have been exploring the Public Accounting Oversight Board (PCAOB) with Joe Howell, an Executive Vice President (EVP) with Workiva Inc. We have considered how some of the issues addressed by the PCAOB directly...more

Does the New FCPA Pilot Program Put the Odds in Disclosing Organizations’ Favor?

“I volunteer as tribute” In The Hunger Games, Katniss Everdeen bravely uttered these words as she stepped forward to take the place of her sister in Panem’s annual fight to the death. While volunteering worked out for...more

[Webinar] FCPA Spotlight: Best Practices for Controls and Records - May 20th, 1:00pm EDT

In this era of increased attention to corruption, the U.S. Justice Department and Securities and Exchange Commission are increasingly using the FCPA's books and records and internal controls provisions to prosecute improper...more

Is the Sky Falling? DOJ and Cooperation

Is the sky falling or are we on our way to a new normal when it comes to earning cooperation credit from the Department of Justice? These questions were raised in remarks by Deputy Attorney General Sally Yates in remarks...more

FinCrimes Update - April 2016 Summary, Volume 4, Issue 4

AML/BSA & OFAC: FINCEN ANNOUNCES DEPARTURE OF DIRECTOR CALVERY - On April 26, FinCEN announced the departure of Director Calvery. Commenting on Calvery’s accomplishments during her tenure as Director, the agency...more

What Can You Learn in the First Inning?

You might figure that the year I decide to jump back on the Houston Astros bandwagon, they go back in the tank. Last year they were one game away from the American League (AL) Championship. This year they have the third worst...more

DOJ Closes FCPA Investigation into Onshore, Rig-based Well Servicing Contractor Without Prosecution; SEC Negotiations Continuing

On April 28, an onshore, rig-based well servicing contractor with operations in the United States, Mexico, and Russia announced that the DOJ had closed its investigation into possible violations of the FCPA in relation to the...more

What is a Compliance Evangelist?

What does it mean to be the Compliance Evangelist? A colleague put that question to me last week. This friend is a loyal and long time reader of my blog and listener of my podcast and I thought if it was not clear to her,...more

Compliance Program Lessons from a Recidivist

Recidivist behavior is something that the US government is forced to face in Foreign Corrupt Practices Act (FCPA) enforcement from time-to-time. When a company agrees to a Deferred Prosecution Agreement (DPA) or...more

DOJ Announces Pilot Program for Self-Reporting FCPA Misconduct

In an effort to move forward with the Department of Justice's (DOJ) policy of individual responsibility, the agency announced a pilot program to encourage corporations to self-report Foreign Corrupt Practices Act (FCPA)...more

U.S. - India Newsletter Vol. 2016, Issue 2

Welcome to the second issue of our newsletter, which features news and articles of interest from Pepper’s U.S.-India Practice. In the first quarter of 2016, we saw a lot of activity in the international data privacy...more

DOJ’s New FCPA “Pilot Program” Targets Corporate Officers and Other Individuals

For years, FCPA observers have predicted that the Department of Justice (“DOJ”) will increase its prosecutions of corporate officers and employees for FCPA violations. These predictions have so far proven disputable, as the...more

Creating a Real Incentive for Self-Reporting FCPA Violations (Part II of II)

Let’s start with a big “If.” I know that sounds like a real turn off but bear with me. Assuming that the Justice Department is ready to turn over a new approach to criminal enforcement and aggressively prosecute culpable...more

To Self-Report or Not to Self-Report, That Remains the Question After the Justice Department’s Latest Effort to Encourage...

On April 5, 2016, the United States Department of Justice, Criminal Division, Fraud Section launched a one-year Pilot Program that invites companies to self-report potential violations of the Foreign Corrupt Practices Act...more

Dorsey Anti-Corruption Digest - April 2016

Welcome to Dorsey & Whitney’s monthly Anti-Corruption Digest. In this digest, we draw together news of enforcement activity throughout the world and aim to reduce your information overload. Our London, Minneapolis, New York...more

Is the DOJ’s New FCPA Pilot Program an Offer You Can’t Refuse?

Earlier this month, Assistant US Attorney Leslie Caldwell announced that the US Department of Justice’s Criminal Division Fraud Section will try to entice companies to self-report potential FCPA issues. The DOJ included...more

Colorado Mining Company Announces FCPA Investigation

Recently, a gold mining company based in Colorado disclosed in its quarterly filings an investigation of certain business activities of the company and its affiliates outside the U.S. for possible violations of the FCPA....more

A transatlantic consideration of recent developments in corporate self-reporting

More carrot, less stick? On 5 April 2016, the Fraud Section of the US Department of Justice’s (DOJ) Criminal Division issued an Enforcement Plan and Guidance (the DOJ Guidance), setting out the steps that it is taking to...more

Shakespeare Week – Part III: Much Ado About Nothing and Incorporation of Social Media into Your Compliance Program

How does Shakespeare portend social media in the 21st century? I would submit that one only need look at Much Ado About Nothing to see how it should all play out. As with all Shakespeare’s plays there is quite a bit going on...more

Federal FCPA Pilot Program Encourages Self-Disclosure and Cooperation

“Voluntary self-disclosure of criminality,” “full cooperation” and “timely and appropriate remediation” in connection with violations of the Foreign Corrupt Practices Act (FCPA) are the main ingredients in the recipe for...more

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