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Third-Party Enforcement Foreign Corrupt Practices Act (FCPA)

NAVEX

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

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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

NAVEX

What a New SEC Enforcement Sweep Is Really Telling Us

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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

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

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

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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

Thomas Fox - Compliance Evangelist

From China to Poland and Brazi l- The Lilly FCPA Enforcement Action- Part II

In Parts II and III of my review of the Eli Lilly and Company (Lilly) Foreign Corrupt Practices Act (FCPA) enforcement action brought by the Securities and Exchange Commission (SEC), I will discuss some the processes and...more

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