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Bass, Berry & Sims PLC

International Trade Enforcement Roundup – September 2024

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What happened? On September 10, the SEC announced that John Deere agreed to pay almost $10 million to resolve allegations it had violated the FCPA. The SEC alleged that Wirtgen Thailand, an indirect subsidiary of John Deere,...more

The Volkov Law Group

DOJ Issues New FCPA Declination: Boston Consulting Group Pays $14.4 Million

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The Justice Department is encouraging companies to voluntarily disclose criminal violations — “Come in and confess” and DOJ offers promises of a declination.  But even a declination comes with a requirement — the company has...more

The Volkov Law Group

Episode 314 -- A Deep Dive into Gunvor's FCPA Settlement

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In a recent blockbuster FCPA settlement, DOJ announced a $661 million resolution with Gunvor, one of the world’s largest commodities trading companies. DOJ’s settlement represents a “return” to its long-standing aggressive...more

The Volkov Law Group

2023 Sanctions Year in Review and Predictions

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As always, I tend to repeat myself.  However, one important point needs to be repeated — DOJ is in the midst of launching an aggressive sanctions and export control program against corporations and individuals.  DOJ has...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for December 2023

Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption law and enforcement developments from the past...more

The Volkov Law Group

SAP Returns to U.S. Enforcement Scene: Pays DOJ and SEC Over $220 Million to Resolve FCPA Violations (Part I of III)

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Life is always filled with surprises.  Just when we thought 2023 was a “slow” FCPA enforcement year, DOJ and SEC announced a large enforcement action against SAP for approximately $220 million for FCPA violations in South...more

Thomas Fox - Compliance Evangelist

The SAP FCPA Enforcement Action-Part 2: The Box Score of Corruption

We continue our exploration of the Foreign Corrupt Practices Act (FCPA) enforcement involving the German software company, SAP. The company agreed to pay the Department of Justice (DOJ) and Securities and Exchange Commission...more

The Volkov Law Group

Albemarle’s Reliance on Third-Parties to Execute Bribery Schemes (Part II of III)

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Albemarle’s bribery schemes look and sound like text-book examples of third-party agents being paid high commissions as a way to funnel bribery payments to foreign officials at state-owned oil refineries.  However, as usual,...more

The Volkov Law Group

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

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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

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for June 2023

Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption law and enforcement developments from the past...more

The Volkov Law Group

Gartner Settles FCPA Case with SEC for $2.5 Million

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The SEC has been racking up several FCPA enforcement actions.  DOJ appears to be declining many of these cases. The division of enforcement appeared to follow a pattern – on larger cases with more pervasive violations, DOJ...more

The Volkov Law Group

DOJ Charges Two Oil and Gas Traders with FCPA Bribery Scheme Involving Petrobras

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In its first enforcement action of 2023, the Justice Department charged a Connecticut man and a foreign national with FCPA bribery and money laundering charges stemming from a bribery scheme to secure contracts with Petrobras...more

The Volkov Law Group

Goldman Sachs Official Indicted Over Ghana Bribery Scheme (Part I of II)

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Talk about a reminder of the past, Asante Berko, a former Executive Director in Goldman Sachs, recently was arrested in London on criminal FCPA charges arising from his involvement in a bribery scheme in Ghana....more

Alston & Bird

Second Circuit Presents U.S. Companies Historic Opportunity to Defend Against FCPA Liability

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The Second Circuit has made the government’s formerly straightforward task of assigning vicarious liability to a corporate principal under the Foreign Corrupt Practices Act considerably harder. Our White Collar, Government &...more

A&O Shearman

Top ten challenges for white-collar crime and investigations lawyers in 2022

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We asked our global white collar crime team for their views on key challenges in 2022 for in house investigations teams and white collar crime lawyers, and how to manage the associated risks. Here are the top ten....more

Thomas Fox - Compliance Evangelist

Compliance Into The Weeds - Year-End Review, Part 2

Compliance into the Weeds is the only weekly podcast that takes a deep dive into a Compliance-related topic, literally going into the weeds to more fully explore a subject. On Tuesday, Matt and I began a special two-part...more

Kramer Levin Naftalis & Frankel LLP

FCPA Enforcement Appears Primed to Reemerge

Over the course of the year — and even dating back to his time on the campaign trail — President Biden and senior officials in his administration, including Department of Justice (DOJ) and Security and Exchange Commission...more

Hogan Lovells

OECD releases latest Anti-Corruption recommendations—most significant Anti-Bribery update since 2009

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On November 25th, the OECD Council for Further Combating Bribery of Foreign Public Officials in International Business Transactions adopted a series of recommendations for member countries to implement, in an effort to curb...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for October 2021

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Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption law and case developments from the past month,...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for September 2021

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Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption law and case developments from the past month,...more

King & Spalding

Q1 2021: Latin American Enforcement Review

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Enforcement authorities throughout the Americas continued investigations of fraud, corruption, and other misconduct across the region. Below are some of the highlights of the last quarter. ...more

Alston & Bird

New Administration, New Enforcement Priorities

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Three weeks into the Biden Administration, businesses must prepare for significant changes in regulatory and enforcement priorities. Our White Collar, Government & Internal Investigations Team summarizes the new...more

The Volkov Law Group

DOJ Cryptocurrency Guidance Outlines Enforcement Partnerships (Part II of II)

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DOJ’s Cyber Digital Task Force’s report, “Cryptocurrency: An Enforcement Framework,” provides a comprehensive on the growing partnerships between DOJ and other offices within the executive branch....more

The Volkov Law Group

Justice Department Indicts Vitol Oil Trader in International Bribery and Money Laundering Conspiracy for Corrupt Payments to...

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A federal grand jury in the Eastern District of New York returned an indictment against Javier Aguilar, an oil trader at Vitol, an energy and commodity trading company, for his role in a five-year international bribery and...more

Foodman CPAs & Advisors

Did you know that the IRS is Involved with Investigating and Prosecuting Bribery?

In 1977, the United States enacted the Foreign Corrupt Practices Act (FCPA).  The FCPA prohibits an offer, payment, promise or the authorization of a payment of money or anything of value (a/k/a bribery) to a foreign official...more

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