Under the second year of the Trump Administration, the biggest story was the increase of corporate declinations one year after the DOJ adopted a permanent FCPA policy incentivizing self-disclosure, cooperation, and...more
1/16/2019
/ Corporate Counsel ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Foreign Corporations ,
Foreign Corrupt Practices Act (FCPA) ,
Internal Controls ,
Securities and Exchange Commission (SEC) ,
Securities Fraud ,
Self-Reporting ,
Subsidiaries ,
Trump Administration ,
White Collar Crimes
The Situation: In United States v. Hoskins, the United States Department of Justice ("DOJ") charged a foreign national who worked in France for a British subsidiary of a French company with conspiring to violate the Foreign...more
Welcome to the 2017-2018 edition of the Jones Day Anti-Corruption Regulation Survey. In 2017 and 2018 to date, there has continued to be an increasing awareness among multinational companies of the significance of...more
4/18/2018
/ Anti-Bribery ,
Anti-Corruption ,
Chief Compliance Officers ,
Corporate Counsel ,
Corporate Governance ,
Corporate Liability ,
Corruption ,
Department of Justice (DOJ) ,
Due Diligence ,
Ethical Standards ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Official ,
Government Officials ,
Internal Audit Functions ,
Internal Controls ,
Risk Assessment ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act ,
Third-Party Risk ,
White Collar Crimes
The Situation: Companies that learn of Foreign Corrupt Practices Act ("FCPA") violations by employees or agents are faced with significant uncertainty as to whether the benefits and risks of self-disclosing the conduct to the...more
12/5/2017
/ Anti-Corruption ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Federal Pilot Programs ,
Federal Sentencing Guidelines ,
Foreign Corrupt Practices Act (FCPA) ,
Remediation ,
Securities and Exchange Commission (SEC) ,
Self-Reporting ,
Voluntary Disclosure ,
White Collar Crimes
On February 8, 2017, the United States Department of Justice ("DOJ") Fraud Section published a blueprint for assessing corporate compliance efforts, titled "Evaluation of Corporate Compliance Programs" ("Guidance"). It...more
3/2/2017
/ Anti-Corruption ,
Board of Directors ,
Compliance ,
Confidential Communications ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Federal Sentencing Guidelines ,
Foreign Corrupt Practices Act (FCPA) ,
Fraud ,
Internal Investigations ,
New Guidance ,
OECD ,
Policies and Procedures ,
Popular ,
Publicly-Traded Companies ,
Risk Assessment ,
Securities and Exchange Commission (SEC) ,
Senior Managers ,
Third-Party Relationships ,
Training