Compliance Perspectives: The Antitrust Division’s Office of Decree Enforcement
Volatile Times in Vapor Intrusion Regulation: A Legal and Technical Update
Investment Management Roundtable Discussion – Regulatory and Enforcement Update
Podcast - Risk Management: Impact of Revised FCPA Policy on International Risk Management Programs
Podcast - Risk Management: Revised FCPA Corporate Enforcement Policy
Day 16 of One Month to More Effective Continuous Improvement-Voluntary Monitoring
Day 7 of One Month to Better Investigations and Report-How Investigations Inform Remediation
Day 22 of One Month to Better Compliance Through HR-10 Questions to Better Operationalize Compliance
FCPA Compliance and Ethics Report-Episode 31-the FCPA Year in Review, Corporate Enforcement Actions
Lessons Learned from the Parker Drilling DPA and Ralph Lauren NPA
Recent Department of Justice (“DOJ” or “Department”) activity on bribery in Mexico and Latin America sends a warning and provides a roadmap to companies doing business there. By following the roadmap, companies may escape...more
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
SCCE’s four-day Compliance & Ethics Essentials Workshop provides comprehensive education on the core elements of a compliance program. The curriculum is ideal for those new to or with little experience in compliance, as well...more
Companies that self-disclose, cooperate, and remediate could benefit from significantly reduced fines and possible declinations even in cases with aggravating factors. In a speech at Georgetown University Law Center on...more
On January 17, 2023, Assistant Attorney General for the United States Department of Justice Kenneth A. Polite Jr. announced significant revisions to the Criminal Division’s Corporate Enforcement Policy (“CEP”). Four months...more
Terrorist financing comes at a price – and in the case of a global building supplies manufacturer that has pleaded guilty in a US court to making payments to terrorist organisations, that price is USD 778 million in fines and...more
The Superior Court of Québec recently published its reasons1 approving Canada’s first remediation agreement under the Criminal Code, which is Canada’s version of a deferred prosecution agreement (DPA). In his reasons, the...more
SCCE’s Compliance & Ethics Essentials Workshop provides a comprehensive introduction to the elements of a compliance program to enable attendees to be a more effective member of the compliance team. The workshop is ideal for...more
On the eve of the July 4th holiday, the Criminal Division of the Department of Justice (the “DOJ”) and the Enforcement Division of the Securities and Exchange Commission (the “SEC”) quietly published the second edition of the...more
Over the past several blog posts, I have been exploring the Airbus SE (Airbus) international anti-corruption settlement in some depth. One of the questions I have had and hopefully raised for readers is not why the overall...more
On January 31, 2020, the Department of Justice (“DOJ”) agreed to resolve allegations that Airbus SE (“Airbus”), a France-based aerospace company, used third-party business partners to bribe government officials and airline...more
On December 6, 2019, Telefonaktiebolaget LM Ericsson (Ericsson or the Company), resolved long-running investigations by the U.S. Department of Justice (DOJ) and the U.S. Securities and Exchange Commission (SEC) into the...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
On 25 November at a sentencing hearing at Southwark Crown Court, Alstom Network UK Limited (ANUK) – a subsidiary of French rail conglomerate Alstom – was fined £15m, plus £1.4m in costs, for conspiring to make corrupt...more
The long-awaited Walmart Inc. (Walmart) Foreign Corrupt Practices Act (FCPA) enforcement action was announced last week. This massive case came in with multiple documents, a long list of instances of bribery and corruption, a...more
• Four years ago, Brazilian authorities began Operation Car Wash, a wide-ranging and still ongoing corruption and money laundering investigation that has spanned 11 countries. • The fallout continues with a recent U.S....more
When it comes to a poster-child for corrupt organizations, there is very little competition that can eclipse Petrobas, the Brazilian state-owned oil and gas company. ...more
There are two distinct themes in FCPA enforcement – the first is consistency, i.e., that some enforcement actions are relatively consistent across the board and, in the last five to ten years, the FCPA caseload has been...more
Canada’s Liberal government recently introduced a bill, known as C-74, that would allow for a type of deferred prosecution agreement called a “remediation agreement” for alleged violations of Canada’s foreign bribery law, the...more
With the close of 2017, FCPA enforcement continues as a major priority for the US Department of Justice. Notwithstanding fears and concerns that the new administration would turn its back on FCPA enforcement, the Justice...more
By now the whole world knows about Sally Yates. We are likely to see a lot more of her as a central figure in Congressional investigations. For some of us who deal with compliance investigations, Sally Yates was famous long...more