I remain amazed at the consistently-high estimates of the percentages of U.S. companies doing business internationally, which do not have FCPA and related anti-corruption policies and programs. Beyond the obvious and...more
I’ve often said (only half-jokingly) for many years—even decades—that in retrospect, it seems that when I graduated with my Juris Doctor degree from Tulane Law School in 1979, “the streets were paved with gold.” Translation:...more
For those of us in the practice who are former (in some cases previously career) prosecutors, we sometimes have to fight the inclination to take for granted some basic – and even critical – steps which companies must take...more
For corporate entities across the entire spectrum—small, medium and (especially) large, both closely held and publicly traded—a virtually unavoidable reality is not if the company will be a victim of an internal crime, but...more
In our last blog, we introduced you to the federal law known as the Dodd-Frank Act/UDAAP, which was enacted and is enforced to protect consumers of financial products or services from any claims, statements, or practices...more
The Dodd-Frank Act makes it illegal for any company which provides any financial products or services to consumers to engage in any acts or practices which are considered to be unfair, deceptive or abusive (“UDAAP”).
The...more
When I first read about the changes to the United States Department of Justice’s official guidance on its long-standing “Evaluation of Corporate Compliance Programs,” I immediately set out to identify, digest, and analyze...more
In 2015, then-Deputy AG Sally Yates (Attorney General Eric Holder’s second-in-command) published DOJ’s new policy statement on the investigation and prosecution of corporate offenses, heavily increasing focus on individuals...more
Previously we introduced you to the FCPA and provided updates about the positive international trends in anti-corruption legislation; efforts to punish and deter bribery; the Organization for Economic Cooperation and...more
1/17/2020
/ Acquisitions ,
Anti-Bribery ,
Anti-Corruption ,
Chief Compliance Officers ,
Civil Liability ,
Compliance ,
Corruption ,
Criminal Penalties ,
Enforcement ,
Foreign Corrupt Practices Act (FCPA) ,
Mergers ,
OECD ,
Ratings ,
Risk Management ,
Transparency International ,
Whistleblowers ,
White Collar Crimes
Previously, we introduced you to this topic and provided updates about the positive international trends in anti-corruption efforts, bribery, and the Organization for Economic Cooperation and Development (OECD). Today, we...more
9/10/2019
/ Anti-Bribery ,
Anti-Corruption ,
Bribery ,
Cooperation ,
Corruption ,
Criminal Investigations ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Self-Reporting ,
Voluntary Disclosure ,
White Collar Crimes
This article, which will be published in three parts, provides a compact overview of recent developments and emerging trends in international anti-corruption laws and compliance programs.
For the last several years, I and...more
Here is a wake-up call for employers thinking about shoring up their immigration compliance process as a New Year’s resolution. U.S. Immigration and Customs Enforcement (ICE) is targeting employers and has dramatically...more
12/18/2018
/ Arrest ,
Audits ,
Criminal Liability ,
Deportation ,
Employer Liability Issues ,
Enforcement Actions ,
Fines ,
Form I-9 ,
Hiring & Firing ,
Immigration and Customs Enforcement (ICE) ,
Immigration Enforcement ,
Personal Liability ,
Popular ,
Risk Assessment ,
Undocumented Immigrants ,
Workplace Investigations
So the landscape—like dunes—shifts yet again…at least regarding what you can and can’t carry onto international flights…well, some of them anyway. Just last week, and driven by DHS’s own acknowledgement that the measure was...more