Episode 116 -- Alstom Executive Convicted of FCPA and Money Laundering Offenses
FCPA Compliance and Ethics Report-Episode 165-BHP FCPA Enforcement and Lessons Learned for the Compliance Practitioner
Bribery & Corruption in the Military. A Front-Line View (Part II)
FCPA Compliance and Ethics Report-Episode 130, The Oscars and Compliance, Part IV with Jay Rosen
FCPA Compliance and Ethics Report-Episode 122-with Matt Kelly on Alstom, Avon and Petrobras
FCPA Compliance and Ethics Report-Episode 121-FCPA Year in Review, Part II
Thinking Compliance When Protecting Your Ideas Internationally
FCPA Compliance and Ethics Report-Episode 66-Visit with the FCPA Professor
Fine Tuning Your Anti Corruption Compliance Program
The FCPA Compliance and Ethics Report, Episode 3
Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption law and enforcement developments from the past...more
When the DSL goes into effect on September 1, 2021, it will impose certain restrictions on a company's ability to transfer data out of China without the prior approval of Chinese authorities. One significant restriction is...more
If one were to reflect upon the providing of gifts and business entertainment to foreign governmental officials, one might reasonably conclude that after 40 years of the FCPA, companies might follow its prescriptions...more
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
Seyfarth Synopsis: Among the latest news reports in the cross-border public corruption space that has legally-minded sports fans talking is that a federal grand jury is investigating Major League Baseball’s international...more
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
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
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
Kilpatrick Townsend Partner Joe Dowdy recently gave a presentation at the Charlotte Chapter of the Association of Corporate Counsel that addressed the enforcement of high-profile federal criminal laws rooted in bribery,...more
The single most frequently asked question by our international clients over the past several months is whether there will be changes in white collar prosecution priorities under the new administration, specifically with...more
When most people across the globe think of Rolls-Royce, one word comes to mind – excellence. Yet that image largely relates to Rolls-Royce Limited, the automobile manufacturer, which was founded in 1909. Just a few years...more
Shearman & Sterling’s bi-annual Trends & Patterns in FCPA Enforcement report provides insightful analysis of recent enforcement trends and patterns in the US, the UK and elsewhere, as well as helpful guidance on emerging best...more
The Och-Ziff enforcement action is replete with examples of failures in due diligence and transaction monitoring compliance. Och-Ziff’s bribery schemes were elaborate and intricate and involved complex transactions,...more
On March 1, 2016, the SEC announced that Qualcomm Incorporated, a San Diego-based wireless telecommunication product company, agreed to pay $7.5 million to settle charges that its actions violated the Foreign Corrupt...more
Last week the Securities and Exchange Commission (SEC) concluded a Foreign Corrupt Practices Act (FPCA) enforcement action against Qualcomm Inc. for violations on the Accounting Provisions of the FCPA, including both the...more
Gifts and hospitality continue to be a key theme in the SEC’s latest FCPA case. The action also involves hiring relatives of officials and ignoring risk in the face of a weak compliance and internal control environment. In...more
In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international anti-corruption developments in the past month, with links to primary...more
When DOJ acts, they like to make a splash. While the FCPA Paparazzi have been lamenting the “slow down” in FCPA enforcement actions and the increase in case closings, DOJ still makes its mark when it acts, and I expect more...more
The SEC has been investigating sovereign wealth funds and issues relating to the hiring of friends and family of foreign officials for some time. Now it has filed a settled action centered on both of those issues which...more
In this episode I review the BHP Billiton FCPA enforcement action brought by the Securities and Exchange Commission. I review the underlying facts and provide some lessons learned for the compliance practitioner. The key...more
In this Part IV of my continued exploration of the Oscars and compliance with Jay Rosen, we look at the touchpoint which Hollywood and the movie industry has which might subject it to FCPA liability. ...more
I am often asked about franchisor liability under the Foreign Corrupt Practices Act (FCPA). Franchising has been a successful model in the US and now many corporations are looking at overseas expansion opportunities....more
Earlier this month, a federal judge in New Jersey held that a secretly recorded conversation between a former chief executive officer and his general counsel may be used by prosecutors as evidence against the former executive...more
In this episode, Compliance Week Editor-in-Chief Matt Kelly and I discuss the Avon and Alstom FCPA enforcement actions and then take a look at the ongoing Petrobras corruption scandal and what it means for Brazil. ...more