News & Analysis as of

Foreign Official Compliance Bribery

Womble Bond Dickinson

Recent Anti-Corruption Updates

Womble Bond Dickinson on

Two recent court Foreign Corrupt Practices Act (FCPA) cases, a significant amendment to the Foreign Extortion Prevention Act (FEPA), and the new pilot whistleblower rewards program show that Anti-Corruption Enforcement...more

ArentFox Schiff

How to Avoid an Independent Compliance Monitor: Lessons From the SAP Settlement

ArentFox Schiff on

This week, SAP SE (SAP), the German-based software company, agreed to pay over $200 million to resolve investigations by the US Department of Justice (DOJ) and US Securities and Exchange Commission (SEC) into violations of...more

The Volkov Law Group

Congress Passes Foreign Extortion Prevention Act in Effort to Address “Demand-Side” of Foreign Bribery Equation

The Volkov Law Group on

On December 14, 2023, Congress passed the Foreign Extortion Prevention Act (“FEPA”) in an effort to address certain deficiencies inherent in the current iteration of the Foreign Corrupt Practices Act (“FCPA”), as part of the...more

BakerHostetler

Congress Expands DOJ’s Power to Prosecute Corruption with the Foreign Extortion Prevention Act

BakerHostetler on

Adding to federal prosecutors’ tool kit in fighting global corruption, on December 14, 2023, Congress passed with bipartisan support, the Foreign Extortion Prevention Act (FEPA). As part of the National Defense Authorization...more

The Volkov Law Group

Lessons Learned from the Albemarle FCPA Enforcement Action: Mind Your Third Parties (Part III of III)

The Volkov Law Group on

The Albemarle FCPA enforcement action was announced at a good time.  This year has been a slow year for DOJ’s FCPA enforcement program, although there are several months before the end of the year. The SEC, on the other hand,...more

Freeman Law

The Foreign Corrupt Practices Act

Freeman Law on

The Foreign Corrupt Practices Act (FCPA), 15 U.S.C. §§ 78dd-1, et seq was signed into law in 1977 by President Jimmy Carter. The FCPA generally prohibits payments to foreign government officials in order to obtain or retain...more

Latham & Watkins LLP

Japanese Ministry of Economy, Trade and Industry Updates Guidance to Prevent Foreign Bribery

Latham & Watkins LLP on

Companies with business operations in Japan should review due diligence procedures and internal policy regarding small facilitation payments to ensure they are consistent with new guidance from METI. In May 2021, the...more

Miller Canfield

Record Level of FCPA Enforcement in 2020 Highlights Key Risk Areas

Miller Canfield on

The year 2020 witnessed a record level of $2.78 billion in corporate fines and penalties from enforcement of the Foreign Corrupt Practices Act (FCPA) by the U.S. Department of Justice (DOJ) and the U.S. Securities and...more

Jones Day

New Guidance for Dutch Prosecutor on the Investigation and Prosecution of Foreign Corruption

Jones Day on

On October 1, 2020, the new Instruction on the Investigation and Prosecution of Foreign Corruption for the Dutch Public Prosecution Service ("DPPS") entered into force, indicating certain factors that play a role in...more

Thomas Fox - Compliance Evangelist

J&F – The Bribery Schemes

Last week, I began a multi-part exploration of one world’s largest anti-corruption enforcement actions, the J&F Investimentos SA (J&F) matter. It involved huge fines and penalties in both Brazil and the United States. Of...more

Thomas Fox - Compliance Evangelist

Farewell to Eddie Van Halen and Joint Venture Risks Under the FCPA

Eddie Van Halen died yesterday. He is the first rocker, more or less, of my generation to die after the age of 60. He was also one of the greatest guitarists ever. Indeed, I would rank him as the best guitarist of his...more

Thomas Fox - Compliance Evangelist

Sargeant Marine – The Individual Guilty Pleas

We rarely have seen a single Foreign Corrupt Practices Act (FCPA) enforcement action generate so many individual criminal pleas. The Sargeant Marine Inc. (Sargeant Marine) case is an exception. To date, there have been six...more

Barnea Jaffa Lande & Co.

The Offense of Bribery

Enforcement authorities have attempted in recent years to increase their war on bribery and corruption. We therefore have seen a number of elected officials investigated for such offenses, viewed as some of the most serious...more

WilmerHale

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

WilmerHale on

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

WilmerHale

Juniper FCPA Settlement Provides Useful Compliance Reminders

WilmerHale on

On August 29, 2019, the Securities and Exchange Commission (“Commission” or “SEC”) agreed to resolve an enforcement action against Juniper Networks, Inc. (“Juniper” or the “Company”), a Silicon Valley-based cybersecurity and...more

King & Spalding

Shifting Dynamics in Latin America

King & Spalding on

On March 5, 2019, King & Spalding hosted an Energy Forum, titled “Shifting Dynamics in Latin America”, to discuss the political and regulatory changes in Latin America and their impact on investments in energy. Latin...more

The Volkov Law Group

Lessons Learned and Trends from MTS FCPA Enforcement Action and Criminal Indictment of Karimova and Akhmedov (Part III of III)

The Volkov Law Group on

The MTS FCPA enforcement action stands as one of several significant prosecutions in FCPA history. The breadth and depth of MTS’ corruption scheme stands as another example of systemic bribery cultures. The details of the...more

The Volkov Law Group

Anatomy of MTS, Karimova and Akhmedov Bribery Scheme in Uzbekistan (Part II of III)

The Volkov Law Group on

The MTS bribery scandal in Uzbekistan represents the culmination of several significant FCPA violations involving VimpelCom, Telia Sonera, MTS, and Gulnara Karimova, the notoriously corrupt daughter of the former Uzbek...more

BCLP

Recent Voluntary Disclosure May Trigger Larger Government FCPA Review of Agribusiness Practices

BCLP on

In its most recent 10-K, CHS, Inc., a global agribusiness dealing in energy, grains and food, revealed that it had self-disclosed to the Department of Justice and the SEC: “potential violations of the FCPA in connection...more

The Volkov Law Group

CEO Falls to SEC FCPA Settlement

The Volkov Law Group on

Companies have definitely matured in the development and implementation of their ethics and compliance programs. Whether the pace has been rapid enough or is too slow, that is a debatable issue. A good litmus test for a...more

Thomas Fox - Compliance Evangelist

Of Piggy Banks and Schemes; The Petrobras FCPA Enforcement Action: Part II

This blog post continues my multi-part exploration of the Petróleo Brasileiro S.A. – Petrobras (Petrobras) Foreign Corrupt Practices Act (FCPA) enforcement action. Today we take up some of the more prominent bribery schemes...more

The Volkov Law Group

United Technologies SEC FCPA Enforcement Action: Gifts, Meals, Entertainment and Travel Abuse and Bribery (Part II of II)

The Volkov Law Group on

When you read through the United Technologies SEC FCPA enforcement action, you cannot help but shake your head – the level of abuse and participation by senior managers in the UT companies – Pratt & Whitney and Otis Elevator...more

Dorsey & Whitney LLP

The FCPA and Foreign Nationals

Dorsey & Whitney LLP on

Despite the fact that the Foreign Corrupt Practices Act has been in force for decades there is relatively little case law interpreting its provisions. A great deal of the existing interpretation of the Act stems from...more

Thomas Fox - Compliance Evangelist

The Credit Suisse FCPA Enforcement Action: Part I – Background

Last week Credit Suisse Group AG (CSAG) and Credit Suisse (Hong Kong) Limited (CSHK), a subsidiary of CSAFG, settled a Foreign Corrupt Practices Act (FCPA) enforcement action for just over $77 million for the illegal hiring...more

BakerHostetler

Foreign Corrupt Practices Act 2017 Year-End Update

BakerHostetler on

2017 marked the fortieth anniversary of the Foreign Corrupt Practices Act (FCPA), and showed continued robust enforcement against both individuals and companies by the U.S. Department of Justice (DOJ) and the U.S. Securities...more

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