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Compulsory Corporate Monitorships: Strategies for Success

Numerous regulatory jurisdictions internationally, as well as multiple nongovernmental organizations (NGOs) such as the World Bank, have increasingly used compulsory corporate monitorships as part of their respective...more

DOJ Continues Focus on Corporate Crime with New Whistleblower Program

On March 7, at the annual American Bar Association (ABA) National Institute on White Collar Crime, US Deputy Attorney General (DAG) Lisa Monaco announced a new whistleblower program that will provide financial rewards to...more

How to Avoid an Independent Compliance Monitor: Lessons From the SAP Settlement

This week, SAP SE (SAP), the German-based software company, agreed to pay over $200 million to resolve investigations by the US Department of Justice (DOJ) and US Securities and Exchange Commission (SEC) into violations of...more

What Does the New FEPA Legislation Mean for FCPA and Anti-Corruption Compliance Programs?

On December 21 President Biden signed the Foreign Extortion Prevention Act (FEPA) as part of the Fiscal Year 2024 National Defense Authorization Act. The legislation addresses a perceived gap in the Foreign Corrupt Practices...more

Show Me the Money: Using Compensation Structures to Promote Compliance

Recent guidance from the US Department of Justice (DOJ) reflects its continued focus on corporate compensation structures to promote compliance. In the past few months, the DOJ has entered into settlement agreements that...more

DOJ Announces New Mergers & Acquisitions Safe Harbor Policy for Voluntary Self-Disclosures

On October 4, Deputy Attorney General Lisa O. Monaco addressed the Society of Corporate Compliance and Ethics and announced a new Department-wide Mergers & Acquisition (M&A) Safe Harbor policy. According to the new policy,...more

Managing Third-Party Risk: Recent FCPA Action Reflects Government’s Continued Focus on Intermediaries

Amec Foster Wheeler Energy Limited (the Company), a subsidiary of John Wood Group plc (Wood), a United Kingdom-based global engineering company, agreed to pay more than $41 million in penalties and disgorgement for alleged...more

Deutsche Bank DPA Reflects Government’s Focus on Third-Party Risk Management and Data-Driven Compliance Programs

On January 8, 2021, US authorities announced that they reached an agreement with Deutsche Bank Aktiengesellschaft (Deutsche Bank) to resolve the government’s investigation into violations of the Foreign Corrupt Practices Act...more

Piercing the Corporate Shell: New Legislation Will Force Anonymous Shell Companies to Disclose Their True Owners

Three months after a leak and investigation into over $2 trillion in suspect transactions at the world’s largest banks and financial institutions, known as the “FinCEN Files,” Congress passed legislation that would require...more

JPMorgan Chase DPA Provides Insight into Government’s Assessment of Compliance Programs

On September 29, 2020, US authorities announced that they reached an agreement with JPMorgan Chase & Co. (JPMorgan Chase) to settle criminal charges related to two distinct years-long market manipulation schemes involving...more

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