Key Takeaways -
As DOJ senior leadership signaled it would do since March, DOJ has now officially required as part of resolving a corporate enforcement action, that a Chief Compliance Officer (CCO) and Chief Executive...more
7/1/2022
/ Anti-Corruption ,
CEOs ,
Certification Requirements ,
Chief Compliance Officers ,
Cooperative Compliance Regime ,
Corporate Misconduct ,
Criminal Liability ,
Department of Justice (DOJ) ,
New Guidance ,
Regulatory Requirements ,
Risk Management ,
White Collar Crimes
At a New York City Bar Association event on April 27, Deputy Attorney General Lisa Monaco described economic sanctions as “the new FCPA.” Her characterization should put corporate compliance departments on notice. ...more
5/6/2022
/ Anti-Corruption ,
Compliance Management Systems ,
Corruption ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Export Controls ,
FCPA Guidance ,
Foreign Corrupt Practices Act (FCPA) ,
Internal Controls ,
Military Conflict ,
Policies and Procedures ,
Russia ,
Ukraine ,
White Collar Crimes
The United States District Court for the Southern District of Texas recently recognized new constitutional and extraterritorial limits on the FCPA. In an order entered November 10, 2021, the court held that it lacked...more
12/3/2021
/ Bribery ,
Constitutional Challenges ,
Corruption ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Due Process ,
Extraterritoriality Rules ,
Foreign Agents ,
Foreign Corrupt Practices Act (FCPA) ,
Indictments ,
Jurisdiction ,
Kickbacks ,
Money Laundering ,
Motion to Dismiss ,
Vagueness ,
White Collar Crimes
Introduction -
China’s top anti-corruption watchdogs recently released a new anti-bribery Guideline designed to focus on multi-national corporations and individuals that pay bribes in China, as opposed to bribe recipients,...more
Key Takeaways - On October 3, 2021, the International Consortium of Investigative Journalists released the “Pandora Papers,” which expose the use by political leaders, billionaires, and others of offshore entities in an...more
On June 1, 2020, the Department of Justice Criminal Division published updated guidance on an important piece of DOJ literature, the “Evaluation of Corporate Compliance Programs” (“Guidance”), which for many is...more