Companies beware! The U.S. Department of Justice (DOJ) announced a pilot program “designed to encourage voluntary self-disclosure by individual participants in certain types of criminal conduct involving corporations.” In...more
The Department of Justice tweaked its FCPA Corporate Enforcement Policy to further incentivize corporations to make voluntary disclosures. These small changes essentially acknowledge that companies in a very early stage of an...more
When DOJ announced its FCPA Corporate Enforcement Policy in 2017 (later expanded to all corporate criminal defendants), defense lawyers expressed concern about a provision buried within what it meant to provide “timely and...more
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
Enforcement of the Foreign Corrupt Practices Act was a high priority for the Department of Justice and the Securities and Exchange Commission in 2016. There's interest in how the new administration could impact enforcement as...more
6/16/2017
/ Alstom ,
Compliance ,
Cooperation ,
Enforcement Actions ,
Enforcement Statistics ,
Federal Pilot Programs ,
Foreign Corrupt Practices Act (FCPA) ,
Halliburton ,
KBR (formerly Kellogg Brown & Root) ,
Popular ,
Siemens ,
Teva Pharmaceuticals ,
Trump Administration ,
Voluntary Disclosure
On March 10, a U.S. Justice Department official announced that agency will continue its one-year Pilot Program, which was introduced by DOJ’s Fraud Section and set to expire on April 5 of this year. As we described in an...more
Enforcement of the Foreign Corrupt Practices Act (FCPA) remained a high priority for the Department of Justice and the Securities and Exchange Commission in 2016, resulting in more than 50 combined enforcement actions, record...more
2/8/2017
/ Books & Records ,
Chief Compliance Officers ,
Declination ,
Department of Justice (DOJ) ,
Disgorgement ,
Enforcement Actions ,
Enforcement Statistics ,
Federal Pilot Programs ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Subsidiaries ,
Securities and Exchange Commission (SEC) ,
Successor Liability ,
Voluntary Disclosure ,
Whistleblowers
On January 6, 2017, the Securities and Enforcement Commission filed an Administrative Action announcing a settlement with two global agribusiness companies. The Order is brief and short on facts. ...more
Breaking new ground, the Department of Justice (DOJ) recently issued two “declinations with disgorgement” to two companies accused of Foreign Corrupt Practices Act (FCPA) violations. These declinations, released under the...more
For the next year, the Justice Department may be offering up to a 50% discount on fines imposed in FCPA cases. Yesterday, the U.S. Department of Justice’s (“DOJ”) Criminal Division announced the launch of a one-year pilot...more
4/7/2016
/ Compliance ,
Cooperation ,
Corporate Counsel ,
Corporate Misconduct ,
Corruption ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Federal Pilot Programs ,
Federal Sentencing Guidelines ,
Foreign Corrupt Practices Act (FCPA) ,
Individual Accountability ,
Remediation ,
Self-Disclosure Requirements ,
Voluntary Disclosure ,
White Collar Crimes