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
ACI is excited to welcome you back in-person to the 14th Advanced Forum on FCPA & Anti-Corruption for the Life Sciences Industry, taking place on July 21–22, 2022 in Boston! Legal and compliance professionals from...more
Tech companies of U.S. origin tend to have compliance programs focused on U.S. laws, including the Foreign Corrupt Practices Act (the "FCPA") and relevant tax and labor laws. The UK has enacted laws covering bribery and...more
I. Introduction: Enforcement Trends and Priorities - Among other significant developments, 2015 saw the U.S. Department of Justice (the “DOJ” or the “Department”) document a policy priority of holding individuals...more
In this episode which is Part II of my look at SEC enforcement of the FCPA, I consider whether profit disgorgement is available to the SEC in a strict liability enforcement action of violation of internal controls. ...more
I conclude my week of exploration of Agatha Christie’s Miss Marple short stories and the Securities and Exchange Commission’s (SEC) enforcement of the Foreign Corrupt Practices Act (FCPA) by reviewing some of the new things...more
In this episode, I pay tribute to Leonard Nimoy and his immortal character Mr. Spock. I also discuss that the SEC may be moving towards a strict liability standard for internal controls under the FCPA....more
I think that a strict liability standard is coming to Foreign Corrupt Practices Act (FCPA) enforcement. A number of factors have caused me to come to this conclusion. While there may well be wide disagreement as to whether...more