Internal Investigations, DOJ | JD Supra Law News

Federal Authorities Announce FCPA Action, First SEC Non-Prosecution Agreement

by BuckleySandler LLP on 5/1/2013

On April 22, the DOJ and the SEC announced parallel actions against a clothing company to resolve allegations that a subsidiary of the company paid bribes to Argentine officials over a several-year period to obtain improper...more

Lessons Learned from the Parker Drilling DPA and Ralph Lauren NPA [Video]

by Thomas Fox on 4/25/2013

In the two most recent corporate Foreign Corrupt Practices Act (FCPA) enforcement actions, the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) to communicate not only what they believe constitutes a...more

Actions Taken During A FCPA Enforcement Action - Lessons From Parker Drilling And Ralph Lauren

by Thomas Fox on 4/25/2013

In the two most recent corporate Foreign Corrupt Practices Act (FCPA) enforcement actions, the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) to communicate not only what they believe constitutes a...more

The Danger Of FCPA “Proactive” Investigations

by Michael Volkov on 4/22/2013

The old adage – if something is too good to be true, it probably is not – applies with equal force in the world of bribery and intrigue. The recent arrest of the mining executive for obstruction of the Justice Department’s...more

How To Demonstrate Ethics And Compliance – Earn It, Re-Earn It And Re-Evaluate It

by Thomas Fox on 4/15/2013

What should your company do if it finds itself in a situation where some of its senior leadership has engaged in conduct which violates its own ethical standards or external legal standard such as the Foreign Corrupt...more

MAS*H and Triage in Your FCPA Investigation Protocol

by Thomas Fox on 4/3/2013

One of the things that I learned from the television series M*A*S*H was the need for triage. In the hospital setting, triage is the process of determining the priority of patients’ treatments based on the severity of their...more

How Does Your Organization Treat Whistleblowers?

by Thomas Fox on 2/8/2013

As almost everyone knows, Lance Armstrong spoke for the first time about his performance enhancing drug (PED) use recently on Oprah. On the first night he admitted for the first time that he used PEDs during his seven wins at...more

Amnesty for Armstrong? Lessons for the Compliance Practitioner

by Thomas Fox on 2/1/2013

The Lance Armstrong saga continues to provide many lessons for the compliance practitioner. A recent article on ESPN.com, entitled “Lance calls for amnesty program”, reported that Armstrong has come out in favor of those who...more

The FCPA Guidance on the Ten Hallmarks of an Effective Compliance Program

by Thomas Fox on 1/23/2013

Many commentators are still mining the Department of Justice (DOJ)/Securities and Exchange Commission (SEC) publication, A Resource Guide to the U.S. Foreign Corrupt Practices Act, (the “Guidance”), which was released last...more

Glengarry Glen Ross and the Internal Marketing of a Compliance Program

by Thomas Fox on 1/16/2013

One of the great plays and movies that I enjoy is ‘Glengarry Glen Ross’. As you might expect with anything that David Mamet pens the dialogue is absolutely spot on, fast paced and non-stop. The action generally revolves...more

Top Ten Enforcement Actions for 2012

by Thomas Fox on 1/8/2013

As we welcome in 2013, it is appropriate to reflect back on some of the things which have occurred over 2012 and in the Foreign Corrupt Practices Act (FCPA) enforcement world, it was quite a significant year. The Department...more

The Lilly FCPA Enforcement Action (Part III) Lessons Learned from Russia

by Thomas Fox on 1/4/2013

This Part III is the final installment of my review of the Eli Lilly and Company (Lilly) FCPA enforcement action brought by the Securities and Exchange Commission (SEC). In this Part III, I will review the FCPA issues that...more

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Internal Investigations › Dept. of Justice

Federal Authorities Announce FCPA Action, First SEC Non-Prosecution Agreement

Lessons Learned from the Parker Drilling DPA and Ralph Lauren NPA [Video]

Actions Taken During A FCPA Enforcement Action - Lessons From Parker Drilling And Ralph Lauren

The Danger Of FCPA “Proactive” Investigations

How To Demonstrate Ethics And Compliance – Earn It, Re-Earn It And Re-Evaluate It

MAS*H and Triage in Your FCPA Investigation Protocol

How Does Your Organization Treat Whistleblowers?

Amnesty for Armstrong? Lessons for the Compliance Practitioner

The FCPA Guidance on the Ten Hallmarks of an Effective Compliance Program

Glengarry Glen Ross and the Internal Marketing of a Compliance Program

Top Ten Enforcement Actions for 2012

The Lilly FCPA Enforcement Action (Part III) Lessons Learned from Russia

Lessons Learned from the Parker Drilling DPA and Ralph Lauren NPA [Video]

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