News & Analysis as of

Non-Prosecution Agreements

Commodity Futures Trading Commission Launches Cooperation Initiative

by Zuckerman Spaeder LLP on

When investigating potential wrongdoing, government investigators have powerful tools that they can use to obtain information. As the U.S. Attorneys’ Manual explains, one such tool is the ability to enter into non-prosecution...more

U.S. Commodity Futures Trading Commission Enters Into Its First Public Non-Prosecution Agreements

by Allen & Overy LLP on

On June 29th, 2017, the U.S. Commodity Futures Trading Commission (CFTC) entered into the first public non-prosecution agreements in its history with three former Citigroup traders, pledging not to pursue civil...more

Bridging the Week - July 2017

Trading Firm and Individual Trader Settle CFTC Allegations of Engaging in Wash Sales to Obtain Exchange Fee Rebates: Rosenthal Collins Capital Markets LLC (now named DV Trading LLC), a proprietary trading firm, settled...more

Will the Justice Department Continue to Use DPAs and NPAs?

by Michael Volkov on

With a new administration at the Department of Justice, practitioners and commentators are looking for signs of change. Given the current politics of the new administration, the Justice Department will undergo changes in...more

Transparency in FCPA Enforcement

by Michael Volkov on

We all value transparency as a general concept, especially when it comes to the government. In a real macro perspective, we fund the government and we demand that our government operate efficiently, effectively and ethically....more

Code of Conduct Week: Part I – Introduction

by Thomas Fox on

I am joined by Eric Morehead as we begin a five-part series on the Code of Conduct, which serves as the foundational document of a compliance program. Morehead is well-known within the compliance community, having worked at...more

How to garner a NPA and Declination

by Thomas Fox on

It certainly did not take long for companies to see the benefit of the Department of Justice (DOJ) Foreign Corrupt Practices Act (FCPA) Pilot Program as there where two public declinations granted by the DOJ for companies...more

Global Anti-Bribery Year-in-Review: 2016 Developments and Predictions for 2017

by WilmerHale on

The past year was consequential for FCPA enforcement in numerous respects, including blockbuster penalties, new policy initiatives, and the SEC’s first DPA with an individual for FCPA violations. In April 2016, the DOJ’s...more

Las Vegas Sands Suffers Double Whammy and Resolves FCPA Action with DOJ for $7 Million

by Michael Volkov on

Following a separate SEC action, the Justice Department resolved FCPA charges against Las Vegas Sands for $7 million. DOJ and Las Vegas Sands entered into a non-prosecution agreement (NPA) citing much of the same evidence...more

General Cable FCPA Enforcement Action – Part III: The Denouement

by Thomas Fox on

This week I have been exploring the General Cable Corporation (General Cable) Foreign Corrupt Practices Act (FCPA) enforcement action. It was settled with the Department of Justice (DOJ) via a Non-Prosecution Agreement (NPA)...more

General Cable FCPA Enforcement Action – Part II: The Comeback

by Thomas Fox on

Yesterday I began an exploration of the General Cable Corporation (General Cable) Foreign Corrupt Practices Act (FCPA) enforcement action. It was settled with the DOJ via a Non-Prosecution Agreement (NPA) and the SEC via a...more

Badda Bing, Badda Boom!! — DOJ and SEC Make 2016 a Record Year for FCPA Enforcement (Part I of III)

by Michael Volkov on

We begin the New Year with a three-part series on the FCPA: (1) A review of FCPA enforcement in 2016; (2) Trends from 2016 FCPA enforcement; and (3) Predictions for FCPA enforcement in 2017....more

General Cable FCPA Enforcement Action – Part I: The Bribery Schemes

by Thomas Fox on

The Department of Justice (DOJ) and Securities and Exchange Commission (SEC) continued their stunning run of 2016 Foreign Corrupt Practices Act (FCPA) enforcement actions right up to the end of the year with the announcement...more

United Airlines Settles with SEC for Side-Stepping Its Own Anti-Corruption Controls: Management Override for a Ride Over to South...

In a settlement highlighting the need for public companies to implement – and adhere to – effective internal controls, United Airlines “United” recently paid a $2.4 million civil penalty to the Securities and Exchange...more

The Chairman’s Flight and the US Corrupt Practices Act

by Thomas Fox on

Earlier this week a most interesting non-Foreign Corrupt Practices Act (FCPA) bribery and corruption enforcement, actions was announced by the Securities and Exchange Commission (SEC). It involved a clear quid pro quo benefit...more

The Domestic Corrupt Practices Act Arrives According to the SEC

The Securities and Exchange Commission announced that the parent company of United Airlines has agreed to pay $2.4 million to settle charges for providing a public official with more convenient flight options. The parent...more

Aggressive Remediation: Embraer and JP Morgan

by Michael Volkov on

There is no question that the Justice Department has raised compliance program expectations in a number of areas. Whatever you may think about the efficacy or fairness of the FCPA Pilot Program, the Justice Department has...more

White Collar Crime Law Enforcement in a Trump Justice Department - 8 Predictions

After a conventional presidential campaign, determining the policy priorities and direction of the incoming administration with respect to the Justice Department’s white collar law enforcement responsibilities can be a...more

Still Serious About Sanctions: OFAC Settles Violations Involving Cuba and Iran

by Bass, Berry & Sims PLC on

Lest U.S. companies think that Cuba and Iran are entirely open for business, a U.S. government settlement announced earlier this month with National Oilwell Varco, Inc. (NOV), a U.S. oilfield services company, will serve as a...more

JPMorgan Sons and Daughters FCPA Enforcement Action, Part III-St. Mark’s Revealed

by Thomas Fox on

This week I am exploring the JP Morgan Chase (JPM) and its subsidiary, JPMorgan Securities (Asia Pacific) Limited (JPM-APAC), (collectively ‘the company’) Foreign Corrupt Practices Act (FCPA) enforcement action which...more

Lessons Learned From FCPA Enforcement Against JP Morgan for Sons and Daughters Referral Program

by Michael Volkov on

Last week, the Justice Department and the SEC finally brought to a close the Sons and Daughters or Princelings investigation. Pending investigations against four other companies still remain to be resolved....more

JPMorgan Sons and Daughters FCPA Enforcement Action: Part I – Venice and Fog

by Thomas Fox on

JP Morgan Chase (JPM) and its subsidiary, JPMorgan Securities (Asia Pacific) Limited (JPM-APAC) resolved its Foreign Corrupt Practices Act (FCPA) matter last week, obtaining a Non-Prosecution Agreement (NPA) from the...more

Volkov on the Evolving Standards for Compliance Programs

by Thomas Fox on

Sometimes I get inspired when writing blog posts and sometimes I get on a roll. It is a bit of both this week and today, as previously this week, I have focused on Department of Justice (DOJ) pronouncements on their view of...more

When Leslie Caldwell Talks FCPA, You Should Listen

by Thomas Fox on

November begins the final push for the compliance conference season, which customarily ends with the ACI National FCPA Conference. During November and into early December, Department of Justice (DOJ) officials have...more

New FCPA enforcement mechanism from the DOJ?

by DLA Piper on

n an aggressive effort to encourage companies to self-report putative violations of the FCPA, the Department of Justice has been touting several recent decisions to decline prosecutions ("declinations") based on the...more

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