The latest revisions to the Evaluation of Corporate Compliance Programs (ECCP) guidance show the Department of Justice (DOJ) is wary about the potential misuse of Artificial Intelligence (AI). Equally captivated are...more
Last week at the 40th American Conference Institute (ACI) International Conference on the FCPA, government enforcement agencies such as the Department of Justice (DOJ), Securities and Exchange Commission (SEC), and UK Serious...more
An Indiana-based contract research organization for pharmaceutical testing is being investigated by the Securities and Exchange Commission (SEC) for potential violations of the Foreign Corrupt Practices Act (FCPA). The...more
Ignoring integrity risks in emerging markets when receiving financing from the World Bank Group (WBG) is about to become much riskier, as the WBG Sanctions System Annual Report for Fiscal Year 2022 (FY22) indicates. The...more
12/7/2022
/ Annual Reports ,
Bid Rigging ,
Collusion ,
Corruption ,
Enforcement Actions ,
Federal Contractors ,
Financial Fraud ,
Financial Institutions ,
Financing ,
Fraud ,
International Finance ,
Investigations ,
Private Sector ,
Project Finance ,
Risk-Based Approaches ,
Settlement ,
Suspensions & Debarments ,
World Bank
The American Bar Association’s annual white collar crime conference is often a favorite place for the U.S. Department of Justice to announce new policies and programs, and this year’s meeting in San Francisco was no...more
On January 21, 2022, the Department of Justice (“DOJ”) issued a Foreign Corrupt Practices Act (“FCPA”) Opinion Procedure Release (the “OPR” or “OPR 22-01”) addressing the rarely discussed extortion exception to the FCPA’s...more
On November 25th, the OECD Council for Further Combating Bribery of Foreign Public Officials in International Business Transactions adopted a series of recommendations for member countries to implement, in an effort to curb...more
12/14/2021
/ Anti-Bribery ,
Anti-Corruption ,
Bribery ,
Compliance ,
Corruption ,
Foreign Corrupt Practices Act (FCPA) ,
Multinational Investigations ,
OECD ,
Popular ,
Public Officials ,
White Collar Crimes
On October 28, 2021, Deputy Attorney General (DAG) Lisa O. Monaco gave the keynote address at the ABA’s 36th National Institute on White Collar Crime and announced a series of changes in the Department of Justice’s (DOJ)...more
Aerospace, defense, and government services – tighter control ahead -
2020 was an eventful year for companies in the aerospace, defense, and government services (ADG) sector. The industry saw arguably the largest...more
This month’s analysis looks at individual prosecutions under the Foreign Corrupt Practices Act (FCPA). Prosecutions have markedly increased over the last five years, and this will better define local, regional, and...more
On June 1, 2020, the U.S. Department of Justice (DOJ), Criminal Division, updated its guidance on the “Evaluation of Corporate Compliance Programs,” providing increased clarity on some of the key questions prosecutors will...more
On November 20, 2019, the U.S. Department of Justice (DOJ) announced several subtle, but important, adjustments to its Foreign Corrupt Practices Act (FCPA) Corporate Enforcement Policy. These recent changes relate to...more
In a May 17, 2019 press report that has been widely distributed in Brazil and the United States, Brazilian Federal Prosecutor Marisa Ferrari confirmed that the U.S. Federal Bureau of Investigation (FBI), the U.S. Department...more
5/21/2019
/ Brazil ,
Bribery ,
Corruption ,
Department of Justice (DOJ) ,
Enforcement Actions ,
FBI ,
Foreign Corrupt Practices Act (FCPA) ,
Government Investigations ,
Kickbacks ,
Medical Devices ,
Multinationals ,
Pharmaceutical Industry ,
Popular ,
Price-Fixing ,
Securities and Exchange Commission (SEC) ,
White Collar Crimes
When a legal team needs to find the facts behind fraud and corruption allegations in a government investigation, technology can drive substantial new efficiencies. ...more
A new plea bargaining system – offering reduced penalties to companies that report certain violations and cooperate with government investigations – will come into effect in Japan this June, reflecting an amendment to the...more