We have received several requests to publish a list of red flags pertinent to multinational organizations. To accommodate these requests, we are publishing a three-part series on anticorruption, export controls and economic...more
3/7/2024
/ Anti-Corruption ,
Antiboycott Requirements ,
Billing ,
Compliance ,
Economic Sanctions ,
Enforcement ,
Ethical Standards ,
Export Controls ,
Foreign Corrupt Practices Act (FCPA) ,
Multinationals ,
Recordkeeping Requirements ,
Reputation Management ,
Risk Assessment ,
Risk Mitigation
In our prior update (published November 29), we provided the first five steps in our twelve-step program for international compliance. These steps are intended to help companies identify international regulatory risk inherent...more
12/14/2023
/ Antiboycott Requirements ,
Audits ,
Compliance ,
Customs ,
Economic Sanctions ,
Export Controls ,
Foreign Corrupt Practices Act (FCPA) ,
Internal Controls ,
Policies and Procedures ,
Risk Assessment ,
SDN List ,
Supply Chain ,
Third-Party ,
Training
Record penalties for violations of U.S. regulations governing international conduct and transactions illustrate the risk of costly enforcement actions facing multinational companies. Yet, many multinational companies lack...more
11/30/2023
/ Anti-Corruption ,
Compliance ,
Customs ,
Economic Sanctions ,
Enforcement Actions ,
Export Controls ,
Internal Controls ,
International Regulatory Standards ,
Office of Foreign Assets Control (OFAC) ,
Penalties ,
Risk Assessment ,
Risk Mitigation ,
SDN List ,
Supply Chain ,
UK Bribery Act ,
USML
The international trade and regulatory environment never has been more difficult for multinational corporations to navigate. For companies that operate, source from, or sell goods, software, or services across borders, legal...more
5/25/2023
/ Anti-Corruption ,
Compliance ,
Department of Justice (DOJ) ,
Enforcement ,
Foreign Corrupt Practices Act (FCPA) ,
International Trade ,
Multinationals ,
Penalties ,
Risk Assessment ,
Risk Mitigation ,
Securities and Exchange Commission (SEC) ,
State-Owned Enterprises
The international trade and regulatory environment never has been more difficult for multinational corporations to navigate. For companies that operate, source from, or sell goods, software, or services across borders, legal...more
5/11/2023
/ Audits ,
Compliance ,
Customs and Border Protection ,
Duties ,
Enforcement ,
False Claims Act (FCA) ,
Forced Labor ,
International Trade ,
Penalties ,
Risk Assessment ,
Tariffs
The unprecedented challenges created by the COVID-19 pandemic and resulting government lockdowns could strain even the most robust compliance programs. Companies have been appropriately focused on business preservation during...more
The U.S. Department of Justice (DOJ) has released updated guidance on evaluating corporate compliance programs. The Evaluation of Corporate Compliance Programs updates prior guidance that was released by DOJ in February 2017....more
On November 29, 2017, Deputy Attorney General Rod Rosenstein announced that the U.S. Department of Justice (DOJ) was issuing a new enforcement policy covering its enforcement of the Foreign Corrupt Practices Act (FCPA). The...more
12/1/2017
/ Anti-Bribery ,
Attorney-Client Privilege ,
Audits ,
corp ,
Corporate Counsel ,
Corporate Criminal Fines ,
Corporate Governance ,
Corporate Misconduct ,
Criminal Investigations ,
Department of Justice (DOJ) ,
Document Productions ,
FCPA Guidance ,
Federal Pilot Programs ,
Fifth Amendment ,
Foreign Corrupt Practices Act (FCPA) ,
New Guidance ,
Recordkeeping Requirements ,
Remediation ,
Risk Assessment ,
Securities and Exchange Commission (SEC) ,
Self-Disclosure Requirements ,
Voluntary Disclosure ,
White Collar Crimes