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
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
The various and elusive tactics used by Russia to evade global sanctions and export controls have grown increasingly sophisticated over the last several months, putting the onus on multinational entities to become equally...more
3/4/2024
/ Belarus ,
Beneficial Owner ,
Bureau of Industry and Security (BIS) ,
Compliance ,
Distributors ,
Due Diligence ,
Economic Sanctions ,
European Commission ,
Evasion ,
Export Controls ,
Foreign Trade Regulations ,
G7 ,
Globally Harmonized System ,
Infrastructure ,
Military Conflict ,
Office of Foreign Assets Control (OFAC) ,
Offshore Companies ,
Risk Management ,
Risk Mitigation ,
Russia ,
SDN List ,
Shell Corporations ,
Supply Chain ,
Tariffs ,
Ukraine ,
US State Departments ,
White Collar Crimes
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
Over the last several months, companies have become entangled in an increasingly complex web of new and expanded sanctions and export control restrictions related to Russia in response to its war on Ukraine. The current...more
11/14/2023
/ Bureau of Industry and Security (BIS) ,
China ,
Compliance ,
Construction Industry ,
Department of Justice (DOJ) ,
Divestment ,
Economic Sanctions ,
Enforcement ,
Export Administration Regulations (EAR) ,
Export Controls ,
Financial Institutions ,
FinCEN ,
Foreign Direct Product Rule ,
Information Technology ,
Manufacturers ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Russia ,
Sanction Violations ,
SDN List ,
Self-Disclosure Requirements ,
Trade Restrictions ,
Ukraine ,
White Collar Crimes