News & Analysis as of

Settlement Foreign Corrupt Practices Act (FCPA)

The Volkov Law Group

DOJ Awards Declination to Proterial Cable America for Fraud — Proterial Pays $15.1 Million in Disgorgement

The Volkov Law Group on

DOJ is pushing hard for voluntary disclosures and urging companies to take advantage  of its Voluntary Disclosure Program.  The carrot is significant — a declination in exchange for cooperation, remediation and disgorgement....more

NAVEX

What a New SEC Enforcement Sweep Is Really Telling Us

NAVEX on

Attention all compliance officers at large technology companies – have you checked your mail lately? Because you might find a letter from the Securities and Exchange Commission with FCPA risk written all over it....more

Nutter McClennen & Fish LLP

Nutter Securities Enforcement Update: March 1, 2024

The Nutter Securities Enforcement Update is a periodic update of noteworthy recent securities enforcement activity, settlements, decisions, and charges. We provide brief summaries that highlight recent enforcement action...more

The Volkov Law Group

Gunvor’s Blockbuster FCPA Settlement: Lessons Learned and Trends (Part III of III)

The Volkov Law Group on

The Department of Justice’s blockbuster FCPA settlement with Gunvor restores the credibility of DOJ’s pronouncements of DOJ’s commitment to aggressive FCPA enforcement.  While I have questioned DOJ’s commitment to its...more

Thomas Fox - Compliance Evangelist

Ten Top Lessons from Recent FCPA Settlements-Lesson No. 10, Getting to Self-Disclosure: Speak Up, Triage and Internal...

Over this series, I have reviewed the messages communicated by the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) from three key Foreign Corrupt Practices Act (FCPA) enforcement actions regarding...more

Adams and Reese LLP

Beyond Borders: Navigating Global Business Compliance with the FCPA

Adams and Reese LLP on

On March 7th, the Department of Justice (DOJ) announced a new whistleblower reward program intended to help prosecutors bring more foreign corruption cases. Under the new program, individuals who report corporate misconduct...more

Thomas Fox - Compliance Evangelist

Ten Top Lessons from Recent FCPA Settlements-Lesson No. 9, Internal Controls

Over the past 15 months the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) has made clear through three Foreign Corrupt Practices Act (FCPA) enforcement actions and speeches, their priorities in...more

Thomas Fox - Compliance Evangelist

Ten Top Lessons from Recent FCPA Settlements – Lesson No. 8, Enhancing Your Compliance Program

Over the past 15 months the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) has made clear through three Foreign Corrupt Practices Act (FCPA) enforcement actions and speeches, their priorities in...more

Thomas Fox - Compliance Evangelist

Ten Top Lessons from Recent FCPA Settlements-Lesson No. 6, Clawbacks and Holdbacks

Over the past 15 months the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) has made clear through three Foreign Corrupt Practices Act (FCPA) enforcement actions and speeches, their priorities in...more

Thomas Fox - Compliance Evangelist

Ten Top Lessons from Recent FCPA Settlements – Lesson No. 4, Start with a Root Cause Analysis

Over the past 15 months, the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) have made clear, through three Foreign Corrupt Practices Act (FCPA) enforcement actions and speeches, their priorities in...more

Thomas Fox - Compliance Evangelist

Ten Top Lessons from Recent FCPA Settlements-Lesson No. 5, Data Analytics

Over the past 15 months, the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) have made clear, through three Foreign Corrupt Practices Act (FCPA) enforcement actions and speeches, their priorities in...more

Thomas Fox - Compliance Evangelist

Ten Top Lessons from Recent FCPA Settlements-Lesson No. 2, the Need for Speed

Over the past 15 months the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) has made clear through three Foreign Corrupt Practices Act (FCPA) enforcement actions and speeches, their priorities in...more

Thomas Fox - Compliance Evangelist

Ten Top Lessons from Recent FCPA Settlements – Lesson No. 1, Self-Disclosure

Over the past 15 months, the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) have made clear, through three Foreign Corrupt Practices Act (FCPA) enforcement actions and speeches, their priorities in...more

Cadwalader, Wickersham & Taft LLP

Insider Trading in Physical Commodities

On December 14, 2023, the Commodity Futures Trading Commission (“CFTC”) and Department of Justice (“DOJ”) Fraud Section announced the settlement of insider trading fraud charges and Foreign Corrupt Practices Act (“FCPA”)...more

ArentFox Schiff

How to Avoid an Independent Compliance Monitor: Lessons From the SAP Settlement

ArentFox Schiff on

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

The Volkov Law Group

DOJ and CFTC Close Out Slow FCPA Enforcement Year with $98 Million Resolution with Freepoint Commodities LLC (Part I of II)

The Volkov Law Group on

The Justice Department’s FCPA enforcement record for 2024 was slow.  This  trend was unexpected, contrary to my own predictions and of various other prognosticators.  It is hard to explain why this slowdown occurred....more

Bass, Berry & Sims PLC

FCPA Enforcement Update: Commodities Trader Agrees to Almost $100 Million Fine

Bass, Berry & Sims PLC on

On December 14, the Department of Justice (DOJ) announced that Freepoint Commodities LLC, a Connecticut-based commodities trader, had agreed to a three-year deferred prosecution agreement (DPA) to resolve a DOJ investigation...more

The Volkov Law Group

Lessons Learned from the Tysers Insurance Brokers and H.W. Wood Limited FCPA Settlements (Part III of III)

The Volkov Law Group on

The Tysers and Wood FCPA settlements reflect something old and something new in the FCPA enforcement world. On the old side, at the core of the FCPA violations was the critical role played by the intermediary company....more

The Volkov Law Group

Two UK Reinsurance Brokers Settle with DOJ for FCPA Violations in Ecuador (Part I of III)

The Volkov Law Group on

DOJ announced two recent FCPA settlements with U.K. based reinsurance brokers involving a long-running bribery scheme involving two Ecuadoran state-owned insurance companies.  While DOJ has had a slow year in FCPA...more

ArentFox Schiff

Show Me the Money: Using Compensation Structures to Promote Compliance

ArentFox Schiff on

Recent guidance from the US Department of Justice (DOJ) reflects its continued focus on corporate compensation structures to promote compliance. In the past few months, the DOJ has entered into settlement agreements that...more

Sheppard Mullin Richter & Hampton LLP

Albermarle Agrees to Pay $218 Million to Settle Foreign Bribery Probe

On September 29, 2023, Albemarle Corporation (“Albemarle”), a global chemical manufacturer, reached an agreement with the U.S. Department of Justice (“DOJ”) and the Securities and Exchange Commission (“SEC”) to resolve...more

Thomas Fox - Compliance Evangelist

Albemarle FCPA Enforcement Action: Part 1 – Background

Last week, Albemarle Corporation (Albemarle), a publicly traded specialty chemicals manufacturing company headquartered in North Carolina, agreed to pay more than $218 million to resolve investigations by the U.S. Department...more

The Volkov Law Group

Albemarle Settles DOJ and SEC FCPA Cases for $218 Million (Part I of III)

The Volkov Law Group on

Albemarle Corporation (Albemarle), a specialty chemicals manufacturing company located in Charlotte, North Carolina, agreed to pay more than $218 million to settle FCPA investigations with DOJ and the SEC stemming from...more

The Volkov Law Group

3M Pays OFAC $9.6 Million to Resolve Egregious Iran Sanctions Violations

The Volkov Law Group on

The past few weeks have not been kind to 3M. The company recently settled with the SEC for $6.5 million to resolve alleged FCPA violations related to its Chinese subsidiary’s dealings with Chinese state-owned healthcare...more

The Volkov Law Group

The Corficocolombiana FCPA Settlement: the Bribery Scheme (Part II of II)

The Volkov Law Group on

You can always learn a lot from reviewing the underlying conduct to an FCPA enforcement action.  Chief compliance officers can identify specific risk factors, mitigation steps and root causes for bribery schemes. ...more

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