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Wal-Mart The Foreign Corrupt Practices Act

Corporate Investigations and White Collar Defense - June 2016

Eye on the Supreme Court—Corruption and Fraud Edition - Why it matters: This session, the Supreme Court has undertaken the review of numerous cases that raise thorny issues arising in the white collar context. In our...more

What Can You Learn in the First Inning?

by Thomas Fox on

You might figure that the year I decide to jump back on the Houston Astros bandwagon, they go back in the tank. Last year they were one game away from the American League (AL) Championship. This year they have the third worst...more

This Week in FCPA-Episode 1 [Video]

by Thomas Fox on

In this initial This Week in FCPA, Episode 1, Jay Rosen and I review this week's happenings in the world of FCPA. Today we discuss the 4th anniversary of the New York Times story about Wal-Mart in Mexico, the Harder guilty...more

The Year 2016 in Compliance

by Thomas Fox on

Greetings from Venice where my wife and I are spending the next few days so this blog post is my first Travel Edition of 2016. Last week I wrote about my thoughts on some of the significant Foreign Corrupt Practices Act...more

Predictions for Anti-Corruption Enforcement for 2016

by Michael Volkov on

In all honesty, if I were betting on my predictions, I would be broke. If I were setting the line on the Super Bowl, I am sure I would go bankrupt in paying off bets. With such confidence, you may want to just click to the...more

Foreign Corrupt Practices Act 2015 Update

by BakerHostetler on

Despite a decline in enforcement actions by the Securities Exchange Commission (“SEC”) and the Department of Justice (“DOJ”), the first half of 2015 has continued to highlight the relevance and ever-evolving effects of the...more

Top Ten International Anti-Corruption Developments for August 2015

by Morrison & Foerster LLP on

In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international anti-corruption developments in the past month, with links to primary...more

Corporate Investigations & White Collar Defense - June 2015

The Unfolding FIFA Scandal: Will the DOJ Show the Banks a Red Card? - Why it matters: The worldwide soccer community has for years decried the brazen corruption that permeated FIFA, international soccer’s governing...more

Why Should Americans Care About the FIFA Indictments? Part III – Corruption and US Companies

by Thomas Fox on

Today, I continue my four-part series on the above question posed to me recently by a colleague. In Part I, I wrote that only the US government had the wherewithal, tools and will to do so. Yesterday, I focused on corruption...more

Compliance Week 2015 Wrap Up

by Thomas Fox on

Compliance Week 2015 has ended. This year was the tenth anniversary of the annual conference and in many ways I found it to be the best one yet. Matt Kelly and his team put together a conference and experience, which was...more

Top Ten International Anti-Corruption Developments for April 2015

by Morrison & Foerster LLP on

1. Criminal Division AAG Promises Increased Transparency in Corporate Charging Decisions. In an April 17, 2015 speech at New York University Law School’s Program on Corporate Compliance and Enforcement, Leslie Caldwell,...more

King Arthur Week – The Quest for the Holy Grail and Compliance Defense – Part V

by Thomas Fox on

We conclude our Arthurian themed week with the Holy Grail, which has fired the imagination of artists for millennia. What was the Holy Grail? According to Professor Dorsey Armstrong in her Teaching Company lecture series,...more

Recent Latin-American Anti-Corruption Investigations and Cases

by Miller Canfield on

In the last few years, several Latin American countries and the United States have increased their focus on anti-corruption matters. This article will survey some of the most significant recent public anti-corruption...more

FCPA Predictions for 2015 (Part II of II)

by Michael Volkov on

The key to being a successful (FCPA) prognosticator is never to keep score. If you do, you are likely to be disappointed. Instead, I follow the strategy of calculated distraction – for example, I predicted last year...more

Delaware Supreme Court Rules That Privileged Documents Must Be Produced To Shareholders Investigating Corporate Misconduct

by Bracewell LLP on

The Delaware Supreme Court recently held that, in certain circumstances, shareholders may be able to obtain access to privileged, internal documents in order to investigate potential breaches of fiduciary duty. In Wal-Mart...more

Land of Confusion: Insurance Coverage for Pre-Suit FCPA Investigation Costs under D&O liability Policies

Bloomberg recently reported that Walmart spent $439 Million in the past two years related to a Foreign Corrupt Practices Act (“FCPA”) investigation . Moreover, Walmart predicts that it will spend an additional $200 Million to...more

Step-by-Step, Inch-by-Inch: Trouble for Wal-Mart in Delaware

by Michael Volkov on

Niagara Falls, slowly I turn, step-by-step, inch-by-inch. In a creative epiphany, I have found a way to link together one of my favorite Three Stooges (Curly was my hero) scenes and Wal-Mart’s current situation in Delaware...more

On The Oregon Trail And Expectations In An Investigation Protocol

by Thomas Fox on

On this day in 1843, a massive wagon train, made up of 1,000 settlers and 1,000 head of cattle, set off down the Oregon Trail from Independence, Missouri. Known as the “Great Emigration,” the expedition came two years after...more

Fcpa Compliance and Ethics Report-Episode 58-Interview with Michael Scher [Video]

by Thomas Fox on

In this episode, I interview Michael Scher about some of the lessons learned from the Wal-Mart investigation. ...more

FCPA Compliance and Ethics Report-Episode 30-Interview with the FCPA Professor-Part 2 [Video]

by Thomas Fox on

This episode 30 is Part 2 of my interview with the FCPA Professor. ...more

Wal-Mart: Be A Leader In Compliance

by Thomas Fox on

In a post last week, entitled “Wal-Mart’s latest FCPA disclosure (October 2013)”, the FCPA Blog reported that Wal-Mart has spent over $155 MM in “costs incurred for the ongoing inquiries and investigations” and costs which...more

FCPA Compliance and Ethics Report-Episode 18-Walmart-Be a Leader in Compliance [Video]

by Thomas Fox on

In this episode 18, I discuss the reasons why Wal-Mart should use its current FCPA issues to become a leader in the area of anti-bribery compliance....more

What Is Board Responsibility For Compliance?

by Thomas Fox on

The nightmare of every corporate director is to wake up to find out that the company of the Board he or she sits on is on the front page of the New York Times (NYT) for alleged illegal conduct. Originally Published in...more

Rolls-Royce Brings in Lord Gold – Is it Thinking Big Enough?

by Thomas Fox on

In December 2012 the BBC online service reported that Rolls-Royce Motor Cars Limited (Rolls-Royce) was in talks with the UK Serious Fraud Office (SFO) regarding potential allegations of bribery and corruption in Indonesia and...more

Fu Manchu and the Wal-Mart FCPA Investigation Water Torture

by Thomas Fox on

Today we celebrate Fu Manchu. No not the facial accouterments but the fictional character who was introduced to the world in a series of novels by British author Sax Rohmer during the first half of the 20th century. He has...more

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