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What Every Multinational Company Should Know About … Anti-Corruption

The international trade and regulatory environment never has been more difficult for multinational corporations to navigate. For companies that operate, source from, or sell goods, software, or services across borders, legal...more

What You Need to Know about the Corporate Transparency Act’s Final Rule

The Final Rule issued under the Corporate Transparency Act (CTA) is, as forecast, a sweeping and significant update to the U.S. anti-money laundering laws, estimated to affect over 32 million entities by requiring new reports...more

SEC Directs Public Companies to Evaluate Disclosure Relating to Russia’s Invasion of Ukraine and Related Supply Chain Issues

On May 3, 2022, the SEC’s Division of Corporation Finance issued guidance through the release of a sample comment letter of public reporting companies’ potential disclosure obligations related to “the direct or indirect...more

Forced Labor Update — Possible Complete XUAR Import Ban

On December 8, the U.S. House of Representatives passed the Uyghur Forced Labor Prevention Act nearly unanimously. The House bill would create a “rebuttable presumption” that all goods from the Xinjiang Uyghur Autonomous...more

What You Need to Know about the Corporate Transparency Act

On January 1, 2021, Congress passed the National Defense Authorization Act for Fiscal Year 2021, which includes the Corporate Transparency Act (the CTA).1 The CTA requires all U.S. businesses to file “beneficial ownership”...more

Reassessing Your Global Compliance Risk Profile

The unprecedented challenges created by the COVID-19 pandemic and resulting government lockdowns could strain even the most robust compliance programs. Companies have been appropriately focused on business preservation during...more

DOJ/SEC Release New Edition of FCPA Resource Guide

On July 3, 2020, the U.S. Department of Justice (DOJ) Criminal Division and the Securities and Exchange Commission (SEC) released the second edition of A Resource Guide to the U.S. Foreign Corrupt Practices Act (the “FCPA...more

Supreme Court Recognizes, Limits SEC’s Disgorgement Power

Three years ago, the Supreme Court ruled in Kokesh v. SEC that disgorgement in the context of an SEC enforcement action functions as a “penalty” for purposes of 28 U.S.C. § 2462 and is therefore subject to a five-year statute...more

Charitable Giving, Government Support and Concession Requests, and Anti-Corruption Compliance in the Time of the Coronavirus...

The COVID-19 pandemic has created hardships across the globe at unprecedented levels – with practically no region or industry unaffected. Governments at all levels across the globe, along with non-governmental and...more

Internal Investigations and Privileges: Two More Courts Rule

Despite the global pandemic, the federal judiciary continues to issue rulings. In the last week, two courts provided guidance about when self-disclosures to the government waive the attorney-client privilege, underscoring the...more

Anti-Bribery Compliance Meets Permits, Approvals and Licences in India

Obtaining permissions, approvals and licences in India creates high risks for bribery on account of there being significant interaction between the company and government authorities. Originally published by IBA...more

Diwali: An Opportune Time for an Anti-Corruption Compliance Reminder

This year, India celebrates Diwali on October 19, 2017. “The Festival of Lights,” as Diwali (or Deepavli) is commonly called, is celebrated across India with great aplomb, joy and, of course, delicious sweets. Diwali...more

Diebold Resolves FCPA Charges for $48 Million

On October 22, 2013, the U.S. Department of Justice (“DOJ”) and the Securities & Exchange Commission (“SEC”) announced their agreements with Diebold Inc. (“Diebold”) regarding probes into alleged bribery of foreign bank...more

Long-Anticipated FCPA Guidance Underscores Need for Effective FCPA Compliance

For 35 years, the U.S. government has enforced the Foreign Corrupt Practices Act (FCPA) while providing an incomplete picture of its views of either effective FCPA compliance or how certain key terms in the statute should be...more

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