On 24 May 2022, Glencore International AG announced a series of coordinated resolutions with various international enforcements agencies including the Department of Justice (”DOJ”), the Commodity Futures Trading Commission...more
6/13/2022
/ Bribery ,
CFTC ,
Conspiracies ,
Corruption ,
Criminal Conspiracy ,
Criminal Forfeiture ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Government Investigations ,
Market Manipulation ,
Plea Agreements ,
Sentencing Factors ,
Serious Fraud Office (SFO) ,
Settlement Agreements ,
Settlement Negotiations ,
UK ,
UK Bribery Act ,
White Collar Crimes
In a closely followed case, on February 26, 2020, a District Court Judge in Connecticut granted Lawrence Hoskins’ motion for acquittal on the seven FCPA counts on which the jury convicted him. Hoskins was a UK citizen who...more
2/28/2020
/ Acquittals ,
Agency Relationship ,
Alstom ,
Bribery ,
Criminal Convictions ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Nationals ,
Indictments ,
Jurisdiction ,
Money Laundering ,
Securities and Exchange Commission (SEC) ,
Subsidiaries
Under the Senior Managers and Certification Regime (“SMCR”), firms are required to identify and report to the FCA any instances of disciplinary action taken in relation to conduct that would amount to a breach of one of the...more
2/10/2020
/ Artificial Intelligence ,
Banking Sector ,
Blockchain ,
Bribery ,
Cartels ,
Corporate Governance ,
Corporate Misconduct ,
Environmental Social & Governance (ESG) ,
EU ,
Financial Conduct Authority (FCA) ,
Financial Institutions ,
Financial Services Industry ,
Hong Kong Securities and Futures Commission (HKSFC) ,
Insurance Industry ,
Payment Systems ,
Risk Management ,
SMCR ,
Technology ,
UK ,
United Arab Emirates (UAE) ,
Whistleblower Protection Policies
Anti-Corruption enforcement remained a top priority in France, the UK, and the US in 2018. Join our firm's Global Anti-Corruption Team as they explain and analyze these three countries' anti-corruption enforcement efforts and...more
12/20/2018
/ Alstom ,
Anti-Bribery ,
Anti-Corruption ,
Bribery ,
Chief Compliance Officers ,
Civil Monetary Penalty ,
Compliance ,
Cooperation ,
Corruption ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
France ,
KBR (formerly Kellogg Brown & Root) ,
Petrobras ,
Risk Management ,
Siemens ,
Teva Pharmaceuticals ,
UK ,
Voluntary Disclosure ,
White Collar Crimes
In its most recent 10-K, CHS, Inc., a global agribusiness dealing in energy, grains and food, revealed that it had self-disclosed to the Department of Justice and the SEC:
“potential violations of the FCPA in connection...more
Anti-Corruption enforcement is a top priority in France, the UK, and the US. Each of these countries has armed its enforcers with the enforcement tools necessary to investigate and prosecute corporations and individuals. Join...more
4/19/2018
/ Acquisitions ,
Anti-Bribery ,
Anti-Corruption ,
Bribery ,
CJIP ,
Corruption ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Official ,
France ,
Internal Audit Functions ,
OECD ,
Sapin II ,
Securities and Exchange Commission (SEC) ,
UK ,
UK Bribery Act ,
White Collar Crimes
On January 16, British engineering group Rolls-Royce Plc announced a global settlement of more than $800 million dollars with anti-corruption authorities in Britain, the U.S. and Brazil, making it the fifth-largest global...more
When asked about the relatively slow year of Foreign Corrupt Practices Act (“FCPA”) prosecutions in 2015, the Chief of the DOJ Criminal Division’s Fraud Section suggested last month: “one year isn’t long enough to tell the...more
2/23/2016
/ Bribery ,
Civil Forfeiture ,
Corporate Counsel ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Government Officials ,
Securities and Exchange Commission (SEC) ,
Telecommunications ,
VimpelCom
The Securities and Exchange Commission’s (SEC) recent Foreign Corrupt Practices Act (FCPA) settlements focus on companies’ lack of sufficient anti-corruption compliance programs, which means, to the SEC, that the companies...more
2/17/2016
/ Anti-Corruption ,
BHP Billiton ,
Books & Records ,
Bribery ,
Compliance ,
Corporate Counsel ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Official ,
Internal Controls ,
SAP SE ,
Securities and Exchange Commission (SEC) ,
Young Lawyers
In planning that trip to promote your products and to qualify under the FCPA affirmative defense of reasonable and bona fide expenditures, whatever you do, DO NOT take any foreign officials to Disneyland. On February 4, 2016,...more