News & Analysis as of

Halliburton Department of Justice (DOJ) Foreign Corrupt Practices Act (FCPA)

Thomas Fox - Compliance Evangelist

The Halliburton FCPA Enforcement Action - Lessons for Chief Compliance Officers on Internal Controls Failures

One takeaway of the Halliburton-Sonangol FCPA enforcement action? Trust but verify....more

Hogan Lovells

Top bribery and corruption developments in 2017 for ADG companies

Hogan Lovells on

In recent years, U.S. and Western European military spending has decreased as military spending in other parts of the world has risen. As a result, aerospace, defense and government services (ADG) companies increasingly rely...more

Snell & Wilmer

The New FCPA Cooperation Plan - Revitalized program or regurgitation of existing policy?

Snell & Wilmer on

On April 5, 2016, the U.S. Department of Justice (DOJ) issued an Enforcement and Guidance Plan (Plan) concerning the Foreign Corrupt Practices Act (FCPA). While the new Plan could be interpreted as a novel departure from past...more

The Volkov Law Group

Private Equity’s Corruption Risk Underbelly — Portfolio Companies

The Volkov Law Group on

FCPA enforcement will likely take a turn into the private equity industry. I know this is a regular claim by FCPA practitioners but we already can see the beginning of the trend. The “princeling” investigations are...more

Thomas Fox - Compliance Evangelist

Economic Downturns and Increased Compliance Risk

Oil is hovering around $50 per barrel. For most of the US economy this drop in oil price has provided a much-needed economic boost. One piece on the NPR website, entitled “Oil Price Dip, Global Slowdown Create Crosscurrents...more

Morrison & Foerster LLP

Top Ten International Anti-Corruption Developments for November 2014

Morrison & Foerster LLP on

For busy in-house counsel and compliance professionals, we have tried to summarize the most important international anti-corruption developments in the past month with links to primary resources. November was definitely a...more

Morrison & Foerster LLP

DOJ’s Second Opinion Release of 2014: Is DOJ Evolving Away from the Halliburton Opinion Standard?

Morrison & Foerster LLP on

The Department of Justice (“DOJ” or the “Department”) just issued its most recent FCPA Opinion Release, only the second in 2014. The Requestor, a publicly traded U.S. consumer products company, sought an opinion as to whether...more

Thomas Fox - Compliance Evangelist

Mergers and Acquisitions Under the FCPA, Part III

Today I conclude my three-part series on mergers and acquisitions under the Foreign Corrupt Practices Act (FCPA) with a review of the post-acquisition phase. Previously many compliance practitioners had based decisions in...more

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