News & Analysis as of

Third-Party Enforcement Department of Justice (DOJ)

NAVEX

Sanctions are the “New” FCPA – How this Era of Enforcement Shapes Third-Party Risk Management

NAVEX on

In the summer of 2022, Deputy Attorney General Lisa Monaco – a veteran prosecutor and currently number two at the helm of the U.S. Department of Justice (DOJ) – began to describe the enforcement of sanctions regulations as...more

White & Case LLP

“Novel” or Not: the SEC and DOJ’s Expansion of Insider Trading to “Shadow Trading” and 10b5-1 Plans Survive Their Days in Court

White & Case LLP on

On April 5, 2024, the U.S. Securities and Exchange Commission ("SEC") won a jury verdict in its first "shadow trading" insider trading action. Only a few weeks before this verdict, a court denied a motion to dismiss a...more

Wiley Rein LLP

Corporate Criminal Enforcement Predictions for 2023

Wiley Rein LLP on

With all eyes turning to 2023, recent Department of Justice (DOJ) corporate enforcement policy changes and clarifications hint at what can be expected from the DOJ in the year ahead. In September, Deputy Attorney General...more

Vinson & Elkins LLP

Recent Guidance from DOJ on the Duress Defense to FCPA Liability

Vinson & Elkins LLP on

In a dramatic departure from prior practice, the U.S. Department of Justice (“DOJ”) recently released its first Opinion Procedure Release (“OPR”) in over eight years, and perhaps responding to criticism from the business...more

Sheppard Mullin Richter & Hampton LLP

CFTC Throws its Hat into the Corporate Compliance Arena

On September 10, 2020, the Commodities Futures Trading Commission (CFTC) issued the latest in a series of circulars regarding corporate compliance released this summer by government agencies. In June, the Criminal Division of...more

Jones Day

DOJ Announces Merger Process Reforms: Déjà Vu All Over Again?

Jones Day on

The Situation: Between 2013 and 2017, the average length of a U.S. Department of Justice ("DOJ") Antitrust Division merger review increased 65 percent to 10.8 months. The Response: DOJ announced reforms to improve...more

Thomas Fox - Compliance Evangelist

FCPA Compliance and Ethics Report-Episode 64-Managing the Third Party Relationship Under the FCPA, Part II

In this episode I continue my review of the five steps of managing third parties under the FCPA. In this part II, I discuss steps 3-5....more

NAVEX

Third Party Risk in a Global Environment

NAVEX on

Most organizations engage with hundreds, if not often thousands, of third party vendors, suppliers, agents and business partners, creating a daunting and ever-expanding scope of risk. This risk arises from: 1....more

Thomas Fox - Compliance Evangelist

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

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

9 Results
 / 
View per page
Page: of 1

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
- hide
- hide