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New Action By The CFTC Means Higher Stakes For Commodity Market Participants

The Commodity Futures Trading Commission (“CFTC”) recently announced the settlement of its first enforcement action involving foreign corruption. In December 2020, the CFTC issued a Consent Order, finding that Houston-based...more

Transparency International’s 2020 Corruption Perceptions Index Indicates Corruption Is Affecting COVID-19 Response

On January 28, 2021, Transparency International released its 2020 Corruption Perceptions Index (“CPI”). Transparency International is an organization focused on stopping global corruption and promoting transparency,...more

Expected Enforcement Trends Under The Biden Administration

On January 20, 2021, Joseph R. Biden, Jr. was inaugurated as the forty-sixth President of the United States. With the change in Presidential administration, we expect new priorities with regard to compliance and...more

FCPA: 2020 Year-In-Review

As we look back on 2020, several FCPA enforcement trends emerge. The following summarizes the key statistics and developments in 2020: •The Department of Justice (“DOJ”) brought 29 enforcement actions in 2020. 7 companies...more

Goldman Sachs Reaches Record $2.9 Billion Settlement Of Malaysia FCPA Violations

On October 22, 2020, the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) announced the coordinated $2.9 billion resolution of a Foreign Corrupt Practices Act (FCPA) enforcement action against The...more

Recent Advisory Opinion Provides Important Guidance To Mitigate Sanctions Risk

Earlier this year, the U.S. Department of State, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), and the U.S. Coast Guard issued a global advisory (the “Advisory”), providing information and...more

Alert: "Essentra Settlement Demonstrates Government Commitment To Compliance Framework"

On July 16, 2020, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced the settlement of apparent violations of the North Korea Sanctions Regulations by Essentra FZE Company Limited...more

Alert: "DOJ Updates Corporate Compliance Evaluation Guidance"

On June 1, 2020, the Department of Justice (DOJ) published an updated version of its guidance for “Evaluation of Corporate Compliance Programs,” originally published in February 2017. The guidance is intended to assist...more

Alert: "Political Retribution In Bridgegate Cannot Sustain Federal Fraud Convictions In Kelly v. United States"

On May 7, 2020, the United States Supreme Court issued a decision in Kelly v. United States, reversing the convictions of Bridget Anne Kelly and William Baroni, two appointees of former New Jersey Governor Chris Christie,...more

Alert: "Key Considerations In The Timing Of FCPA Violation Disclosures"

In November 2019, the U.S. Department of Justice (“DOJ”) issued revisions to the Foreign Corrupt Practices Act (“FCPA”) Corporate Enforcement Policy (“Policy”). The Policy, which was first introduced in 2016, offers...more

Alert: "Texas Governor Defines 'Essential Services'"

On March 31, 2020, Governor Greg Abbott issued Executive Order GA-14 (the “Order”) in response to the COVID-19 pandemic. The Order took effect at 12:01 A.M. on April 2, 2020 and is set to expire on April 30, 2020. Pursuant...more

Alert: "Ensuring Compliance During The COVID-19 Pandemic"

The COVID-19 pandemic national emergency has changed the way organizations are conducting business. As businesses adapt and begin to adjust to this new environment, it is important not to lose sight of the policies and...more

Alert: "Former Alston S.A. Exec’s FCPA Conviction Overturned"

As we discussed in our December 2019 Compliance Alert, former Alston S.A. senior executive Lawrence Hoskins was convicted in November 2019 by a Connecticut jury on six counts of violating the Foreign Corrupt Practices Act...more

Alert: "Astros Scandal Demonstrates Importance Of Tone At The Top"

On January 13, 2020, Major League Baseball (MLB) announced the findings of an investigation into allegations that the Houston Astros had engaged in sign stealing during the 2017 and 2018 seasons. The investigation determined...more

2/4/2020  /  Baseball , MLB , Sports

Alert:"FCPA: 2019 Year-In-Review"

As we look back on 2019, several FCPA enforcement trends emerge. The following summarizes the key statistics and developments in 2019: The Department of Justice (“DOJ”) brought 29 enforcement actions in 2019. 12 guilty...more

Alert: "Former Alstom Exec's FCPA Conviction Demonstrates Reach Of U.S. Bribery Laws"

On November 8, 2019 former Alstom S.A. senior executive Lawrence Hoskins was convicted on six counts of violating the Foreign Corrupt Practices Act (“FCPA”), three counts of money laundering, and two counts of conspiracy for...more

Alert: "The Treasury Department Issues A Framework For OFAC Compliance"

Earlier this year, the U.S. Department of the Treasury issued a new “Framework for OFAC Compliance Commitments” (the “Framework”). The Office of Foreign Asset Control (“OFAC”) is the Treasury Department’s arm that administers...more

Alert: "Tips For Conducting An Effective Internal Investigation" [Part 2]

In our last alert, we discussed three tips to ensure an effective internal investigation: (1) develop and follow internal policies; (2) identify the audience that will evaluate and make decisions at the outset of the...more

Alert: "Tips For Conducting An Effective Internal Investigation" [Part One]

Whether big or small, internal investigations require companies to mobilize their resources efficiently and effectively. Internal investigations can be driven by external sources like the government or a lawsuit, while others...more

Alert: "FCPA: Mid-Year Review"

With the first half of 2019 in the rearview mirror, it is a good opportunity to review the overall trends in Foreign Corrupt Practices Act (“FCPA”) enforcement actions brought by the Department of Justice (“DOJ”) and...more

Alert: "DOJ And SEC Reach Settlement With Walmart For FCPA Violations"

The Department of Justice (“DOJ”) and Securities and Exchange Commission (“SEC”) announced on June 20, 2019 that Walmart, Inc. (“Walmart”) agreed to pay a combined total of $282.7 million to resolve the years-long...more

Alert: "Integrity Compliance for Small and Medium Sized Companies" [Part 3]

As discussed in Part 1 and Part 2 of this series, the seven core principles of an effective integrity compliance program apply to businesses of any size, but there is no one-size-fits-all model to compliance. What is...more

Alert: Integrity Compliance For Small And Medium Sized Companies [Part 2]

In our last alert, we discussed the first three fundamental categories of an effective compliance program: (1) Risk Assessment; (2) Management Buy-in; and (3) Code of Conduct [see our previous alert for the full discussion ...more

Alert: "Integrity Compliance For Small And Medium Sized Companies" [Part 1]

Never has the need for anti-corruption compliance programs for American companies been greater than it is today. This is not only for large multi-national companies, but for small to medium-sized businesses, particularly...more

Breaking Alert: "CFTC Announces Enforcement Guidelines"

On March 6,2019, at the ABA’s National Institute on White Collar Crime, Jamie McDonald, the Director of the Commodity Futures Trading Commission’s (“CFTC”) Division of Enforcement, announced the publication of a new...more

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