Over the last 10 years, 143 companies have paid a combined $10.9 billion to resolve Foreign Corrupt Practices Act cases.
That staggering price tag shows the U.S. Department of Justice’s willingness to go after alleged...more
The International Organization for Standardization (“ISO”) recently published ISO 37001, the first international anti-bribery management system standard. ISO, a Swiss-based international organization, is well known for...more
Although poor, out-of-touch Dr. Evil of the Austin Powers series had to resort to the threat of using a giant laser beam to decimate various cities to try to obtain his one million billion dollars in ransom, Kim Jong-un1...more
On April 5, 2016, the Department of Justice’s (“DOJ”) Fraud Section Chief, Andrew Weissmann, issued a memo (the “Weissmann Memorandum”) announcing a one-year Pilot Program that offers a carrot and stick approach to...more
4/11/2016
/ Bribery ,
Compliance ,
Cooperation ,
Corporate Misconduct ,
Criminal Prosecution ,
Declination ,
Department of Justice (DOJ) ,
Federal Pilot Programs ,
Federal Sentencing Guidelines ,
Foreign Corrupt Practices Act (FCPA) ,
Individual Accountability ,
Internal Investigations ,
Remediation ,
Self-Disclosure Requirements ,
Voluntary Disclosure ,
White Collar Crimes
As reported by the Department of Justice (DOJ) in a December 2015 press release, the False Claims Act (FCA) remains the federal government’s primary means for combating fraud. In 2015, the DOJ recovered $3.583 billion in FCA...more
Now that the Obama administration has loosened its restrictions on Cuba, you’re ready to sell your widgets to a Havana factory, right? Not so fast! Although you may be able to do some things in or with Cuba that you couldn’t...more
10/5/2015
/ Cuba ,
Economic Development ,
Embargo ,
Export Controls ,
Exports ,
Imports ,
Multinationals ,
Obama Administration ,
Office of Foreign Assets Control (OFAC) ,
Sanctions ,
Vessels
The False Claims Act (FCA) imposes liability on individuals and companies who defraud or submit false claims to the federal government. The FCA allows the federal government to seek treble damages, civil penalties and...more
Watch out! Recent enforcement actions illustrate that the US export laws apply to foreign companies too (including your foreign subsidiary or parent).
The US Bureau of Industry and Security (“BIS”) recently announced a...more