FCPA Compliance Report-Bonus Episode, the Walmart FCPA Enforcement Action
This Week in FCPA-Episode 159, week ending June 21, 2019 – the KPMG Trainwreck and Walmart Settles
This Week in FCPA-Episode 80, The Last Jedi Edition
This Week in FCPA-Episode 77, the Home for the Holidays Edition
Day 20: What Does Innovation in Compliance Look Like?
This Week in FCPA-Episode 56
This Week in FCPA-Episode 1
Fcpa Compliance and Ethics Report-Episode 58-Interview with Michael Scher
FCPA Compliance and Ethics Report-Episode 30-Interview with the FCPA Professor-Part 2
FCPA Compliance and Ethics Report-Episode 18-Walmart-Be a Leader in Compliance
In a record year, there are bound to be numerous interesting enforcement actions and principles. I picked out a few to highlight....more
Happy New Year!! In the FCPA arena, 2019 was a record year – in enforcement and compliance. Many continuing trends are becoming more than trends – meaning they are turning into established practices....more
This issue of Skadden’s semiannual Cross-Border Investigations Update takes a close look at recent cases, regulatory activity and other key developments, including a review of the first year of GDPR enforcement, analysis of...more
The Department of Justice (“DOJ”) and Securities and Exchange Commission (“SEC”) announced on June 20, 2019 that Walmart, Inc. (“Walmart”) agreed to pay a combined total of $282.7 million to resolve the years-long...more
This is a tough posting – frankly, there are so many lessons learned from the Walmart case that they could fill a book, or an e-book at least. I will focus on some of the big issues....more
I am at the end of this exploration of the Walmart Inc. (Walmart) Foreign Corrupt Practices Act (FCPA) enforcement action. This massive case came in with multiple documents, a long list of instances of bribery and corruption,...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
The Walmart case, from a big picture standpoint, represents a serious warning to all global companies committed to rapid international growth. In the absence of a significant and sustained commitment to compliance, rapid...more
Our long national nightmare is over – President Gerald Ford, August 9, 1974 - So, $900 million and roughly 8 years later, DOJ and the SEC announced the end of the Walmart FCPA enforcement action. (DOJ and SEC). The...more
June 20, 2019 – Walmart (NYSE: WMT) and its subsidiary, WMT Brasilia, agreed to a combined criminal penalty and disgorgement of $282M, together with WMT’s criminal guilty plea and undertakings in an NPA, to reach a global...more
The big one finally is resolved. The long-awaited Walmart Inc. (Walmart) Foreign Corrupt Practices Act (FCPA) enforcement action was announced yesterday. This massive case came in with multiple documents, a long list of...more
Deputy Attorney General Rod Rosenstein announced the addition of a new Department of Justice (DOJ) Foreign Corrupt Practices Act (FCPA) policy, titled the FCPA Corporate Enforcement Policy. The new policy, which was...more
This week, Jay and I have a wide-ranging discussion on some of the week’s top compliance related stories. We discuss: 1. The Kokesh case at the US Supreme Court is significant for SEC enforcement of the FCPA around profit...more
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
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
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
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
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
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 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
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
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
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
This episode 30 is Part 2 of my interview with the FCPA Professor. ...more
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