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Foreign Corrupt Practices Act (FCPA) Corporate Culture Corruption

Thomas Fox - Compliance Evangelist

Deere FCPA Enforcement Action: Lessons on Pre-Acquisition Due Diligence in M&A

We recently had a Foreign Corrupt Practices Act (FCPA) enforcement action that reminded me that everything old is new again in anti-corruption compliance. The Securities and Exchange Commission (SEC) FCPA enforcement action...more

Thomas Fox - Compliance Evangelist

Culture Week: Part 3- A Toxic Culture and the Fraud Triangle

We continue our exploration of corporate culture. Today, we consider the intersection of the Fraud Triangle and a toxic culture. The Fraud Triangle is well-known to most compliance practitioners. It is pressure, opportunity,...more

Thomas Fox - Compliance Evangelist

Argentieri at ABA White Collar Conference: Compliance Programs, Part 2

There were recently two significant speeches by Department of Justice (DOJ) officials at the American Bar Association National Institute on White Collar Crime. The first was by Deputy Attorney General Lisa Monaco....more

Latham & Watkins LLP

DOJ Announces New Whistleblower Program

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DOJ unveils a new whistleblower incentive program to complement the Department’s continued efforts to encourage self-reporting of criminal violations. On Thursday, March 7, 2024, US Deputy Attorney General Lisa Monaco...more

Miles & Stockbridge P.C.

DOJ Provides a Contemporary Spin on ‘Wanted’ Posters: New Whistleblower Rewards Program Announced

U.S. Deputy Attorney General Lisa Monaco delivered keynote remarks March 7 at the American Bar Association’s 39th National Institute on White Collar Crime. Emphasizing the need for a culture of compliance, Monaco highlighted...more

Thomas Fox - Compliance Evangelist

Leadership’s Conduct at the Top

The 2022 Monaco Memo emphasized the basic point that the key to every company is culture. The bottom line is that corporate culture matters and corporate culture that fails to hold individuals accountable, or fails to invest...more

Thomas Fox - Compliance Evangelist

Albemarle FCPA Enforcement Action: Part 3 – The Comeback

Last week, Albemarle Corporation (Albemarle), agreed to pay more than $218 million to resolve investigations by the U.S. Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) into violations of the...more

Thomas Fox - Compliance Evangelist

Infortal Worldwide Geopolitical Risk Intelligence 2023 Outlook: Part 3-Corruption Intelligence

I recently had the opportunity to visit with, Chris Mason, VP Global Compliance & Investigations at Infortal Worldwide and Dr. Ian Oxnevad, Director, Geopolitical Risk at Infortal Worldwide for a sponsor podcast on Infortal...more

Thomas Fox - Compliance Evangelist

Building a Stronger Culture of Compliance Through Targeted and Effective Training: Part 4-A Training Program for 3rd Parties

Welcome to a special 5 part blog post series on building a stronger culture of compliance through targeted and effective training, sponsored by Diligent. Over this series I will visit with Kunal Agrawal, Director of Customer...more

The Volkov Law Group

Lessons Learned from Ericsson’s DPA Breach: An Internal Investigation Nightmare (Part III of III)

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This is not your typical FCPA enforcement action Lessons Learned column.  Instead, Ericsson’s breach of its DPA presents a laundry list of internal investigation errors – as a practitioner in this area, this is the nightmare...more

The Volkov Law Group

Stericycle DOJ and SEC FCPA Settlement: Lessons Learned (Part III of III)

The Volkov Law Group on

The Stericycle FCPA case is yet another example of a complete culture and compliance breakdown.  As I often repeat myself, there is no more important control than an ethical culture.  When a culture veers into the unethical...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

Jenner & Block

Anti-Corruption Enforcement - 2021 Year in Review

Jenner & Block on

Due to the impact of the COVID-19 pandemic, and the change in presidential administrations in the United States in January 2021, US enforcement of the Foreign Corrupt Practices Act (FCPA) declined in 2021. However, we...more

The Volkov Law Group

2022 Ethics and Compliance Predictions

The Volkov Law Group on

Ethics and compliance professionals believe in their mission – if they did not, they would not be in the field. E&C professionals believe in the power of positive thinking, ethical conduct, and in the overall ability of an...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

The Volkov Law Group

Remediating the Organization’s Culture (Part IV of IV)

The Volkov Law Group on

“The truest measure of an effective compliance program is how it responds to misconduct.”— FCPA Guidance (2d. ed 2020) - This straight-forward statement (above) of a company’s commitment to its “effective” compliance...more

American Conference Institute (ACI)

[Event] Anti-Corruption London - November 2nd - 3rd, London, United Kingdom

C5's 15th International Conference on Anti-Corruption London will take place November 2 – 3, 2021 in Millennium Hotel London Knightsbridge, London. Join your peers for the IN-PERSON reunion of the legal and compliance...more

Society of Corporate Compliance and Ethics...

[Event] Basic Compliance & Ethics Academy - August 9th - 12th, New Orleans, LA

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

The Volkov Law Group

Deutsche Bank FCPA and Fraud “Spoofing” Settlement: A Review of Deutsche Bank Conduct (Part II of II)

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Deutsche Bank’s ethics and compliance function faces numerous challenges.  Deutsche Bank has a storied record of scandals, government enforcement actions and failures to abide by prior deferred prosecution agreements (DPAs)....more

Cadwalader, Wickersham & Taft LLP

Time to Revisit Your Company’s Compliance Culture: A Checklist for Evaluating Corporate Compliance Programs under DOJ’s June 2020...

On June 1, 2020, DOJ updated the guidance that its prosecutors use to evaluate corporate compliance programs. The guidance is critical to companies subject to the FCPA and other corporate criminal liability, as it informs...more

Thomas Fox - Compliance Evangelist

The Astros Players and Communicating Compliance

The Houston Astros sign-stealing scandal is only going to get worse and worse. In addition to the report by Wall Street Journal (WSJ) of the “Dark Arts” program by the Astros front office to steal signs in a program called...more

The Volkov Law Group

Airbus Systemic Bribery and Export Violations: Understanding How a Company’s Compliance Program and Culture Failed (Part IV of IV)

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When reviewing a major enforcement case, I always ask two basic questions: What was the role of Board and senior management in the failure, and how did they fail to exercise proper oversight and ensure compliance?...more

Thomas Fox - Compliance Evangelist

Measuring, Assessing and Improving Culture

As most compliance practitioners know, the Department of Justice’s (DOJ) Evaluation of Corporate Compliance Programs, 2019 Guidance, concentrated focus on culture in a way the DOJ has not done previously. This concentrated...more

Thomas Fox - Compliance Evangelist

The Astros Cheating Scandal and Compliance – Part 5: The Whistleblower and The Amnesty

I am nearing the end of a multi-part exploration of the Major League Baseball (MLB) investigation into allegations that the Houston Astros engaged in a multi-year scheme to steal signs and signals from opposing teams. ...more

WilmerHale

$1 Billion Ericsson Resolution, Three Jury Verdicts Cap Off Busy Fourth Quarter for US FCPA Enforcement

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On December 6, 2019, the Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) agreed to resolve allegations that multinational telecommunications company Telefonaktiebolaget LM Ericsson (Ericsson or...more

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