U.S. Foreign Corrupt Practices Act (FCPA) enforcement activity may be at a temporary standstill, but that should not mean much for the day-to-day operations of global anti-corruption compliance programs. If the Department of...more
2/13/2025
/ Anti-Corruption ,
Bribery ,
Compliance ,
Department of Justice (DOJ) ,
Due Diligence ,
Enforcement Actions ,
Executive Orders ,
FEPA ,
Foreign Corrupt Practices Act (FCPA) ,
Money Laundering ,
Regulatory Agenda ,
Regulatory Freeze ,
Regulatory Reform ,
Risk Management ,
Smuggling ,
Supply Chain ,
Trump Administration ,
White Collar Crimes
As the interplay between export controls, trade sanctions, and anticorruption enforcement continues to intensify, multinational companies must remain vigilant in ensuring that their compliance programs address the many...more
9/25/2024
/ Anti-Corruption ,
Boycotts ,
Bureau of Industry and Security (BIS) ,
Compliance ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement ,
Export Administration Regulations (EAR) ,
Export Controls ,
FinCEN ,
Foreign Corrupt Practices Act (FCPA) ,
Fraud ,
Multinationals ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Penalties ,
Popular ,
Russia ,
Sanction Violations ,
Self-Disclosure Requirements ,
Supply Chain ,
Ukraine ,
Voluntary Disclosure
For years, Department of Justice officials have stressed how important chief compliance officers are as the first line of defense in fighting corporate crimes. While that’s true, compliance programs now have a competitor in...more
6/7/2024
/ Bribery ,
CFTC ,
Compliance ,
Corporate Crimes ,
Department of Justice (DOJ) ,
Enforcement ,
Federal Pilot Programs ,
Financial Crimes ,
Foreign Corrupt Practices Act (FCPA) ,
Fraud ,
Investigations ,
Jurisdiction ,
Kickbacks ,
Money Laundering ,
Non-Prosecution Agreements ,
Securities and Exchange Commission (SEC) ,
Self-Disclosure Requirements ,
Voluntary Disclosure ,
Whistleblower Awards ,
Whistleblowers ,
White Collar Crimes
Recent legislative developments in the United Kingdom, public remarks from the new director of the UK Serious Fraud Office (SFO), and recent parliamentary hearings on the Post Office Horizon scandal put a spotlight on...more
3/15/2024
/ CFTC ,
Compliance ,
Corporate Misconduct ,
Financial Conduct Authority (FCA) ,
Fines ,
Foreign Corrupt Practices Act (FCPA) ,
Incentives ,
Libor ,
Penalties ,
Policies and Procedures ,
Proposed Legislation ,
Reporting Requirements ,
Securities and Exchange Commission (SEC) ,
Serious Fraud Office (SFO) ,
UK ,
UK Parliament ,
Whistleblower Awards ,
Whistleblower Protection Policies ,
Whistleblowers ,
White Collar Crimes
In December 2023, President Joe Biden signed the Foreign Extortion Prevention Act (FEPA) into law under the broader Fiscal Year 2024 National Defense Authorization Act (NDAA). While FEPA’s sponsors hailed it as “the most...more
3/1/2024
/ Anti-Bribery ,
Anti-Corruption ,
Bribery ,
Chief Compliance Officers ,
Compliance ,
Cooperation ,
Department of Justice (DOJ) ,
FEPA ,
Foreign Corrupt Practices Act (FCPA) ,
Fraud ,
Investigations ,
Jurisdiction ,
NDAA
In early October 2023, Deputy Attorney General (DAG) Lisa Monaco announced a “new” (but not new) Department of Justice (DoJ) policy intended to incentivize acquiring companies to voluntarily self-disclose criminal misconduct...more
1/30/2024
/ Acquisitions ,
Department of Justice (DOJ) ,
Due Diligence ,
Foreign Corrupt Practices Act (FCPA) ,
Life Sciences ,
Mergers ,
Risk Assessment ,
Safe Harbors ,
Self-Disclosure Requirements ,
Voluntary Disclosure ,
White Collar Crimes
Juggling conversations with multiple enforcement agencies simultaneously in the course of a cross-border anticorruption investigation can be a difficult and daunting task for legal and compliance teams. Getting it right can...more
4/18/2023
/ Anti-Corruption ,
Compliance ,
Cross-Border ,
Department of Labor (DOL) ,
Enforcement Authority ,
EU ,
Financial Conduct Authority (FCA) ,
Foreign Corrupt Practices Act (FCPA) ,
Fraud ,
General Data Protection Regulation (GDPR) ,
Investigations ,
UK
For more than two years now, heads of the U.S. Department of Justice have maintained a steady drumbeat that they expect companies today to have in place a sound data analytics compliance program to proactively mitigate risks....more
3/2/2023
/ Analytics ,
Anti-Corruption ,
Artificial Intelligence ,
CFTC ,
Compliance ,
Corporate Crimes ,
Corporate Misconduct ,
Data Collection ,
Department of Justice (DOJ) ,
Enforcement ,
Ethics ,
Foreign Corrupt Practices Act (FCPA) ,
Machine Learning ,
Risk Mitigation ,
Securities and Exchange Commission (SEC)
In line with the Biden administration’s declaration last year that anticorruption is a “core United States national security interest,” sanctions evasion enforcement rapidly has become a core priority for the Department of...more
7/12/2022
/ Anti-Corruption ,
Best Practices ,
Compliance ,
Corporate Crimes ,
Cross-Border Transactions ,
Cyber Crimes ,
Department of Justice (DOJ) ,
Due Diligence ,
Economic Sanctions ,
Enforcement Actions ,
Financial Institutions ,
FinCEN ,
Foreign Corrupt Practices Act (FCPA) ,
Money Laundering ,
Multinationals ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Sanction Violations ,
Terrorist Financing ,
U.S. Treasury