On April 2, California Attorney General (AG) Rob Bonta issued an alert reminding businesses operating in California that it is illegal to violate the Foreign Corrupt Practices Act (FCPA)....more
4/10/2025
/ Anti-Corruption ,
Bribery ,
California ,
Compliance ,
Corporate Governance ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Regulatory Requirements ,
State Attorneys General ,
Unfair Competition Law (UCL)
This past September, the US Department of Justice (DOJ) updated its Evaluation of Corporate Compliance Programs (ECCP). The revised guidance reflects the government’s evolving expectations regarding corporate responsibility...more
11/18/2024
/ Anti-Retaliation Provisions ,
Artificial Intelligence ,
Code of Conduct ,
Compliance ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Employee Training ,
Incentives ,
NIST ,
Risk Management ,
Technology ,
Whistleblower Hotlines ,
Whistleblowers
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
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
1/15/2024
/ Bribery ,
Clawbacks ,
Compliance ,
Corporate Counsel ,
Department of Justice (DOJ) ,
Due Diligence ,
Ethics ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Official ,
Instant Messaging Apps ,
Policies and Procedures ,
Political Contributions ,
Remediation ,
Risk Assessment ,
SAP SE ,
Securities and Exchange Commission (SEC) ,
Settlement
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
12/28/2023
/ Anti-Corruption ,
Bribery ,
Compliance ,
Corporate Counsel ,
Department of Justice (DOJ) ,
Due Diligence ,
FEPA ,
Foreign Corrupt Practices Act (FCPA) ,
Investigations ,
NDAA ,
Policies and Procedures ,
Risk Assessment ,
Securities and Exchange Commission (SEC)
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
11/15/2023
/ Anti-Corruption ,
Clawbacks ,
Compensation ,
Compliance ,
Corporate Misconduct ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Enforcement ,
Foreign Corrupt Practices Act (FCPA) ,
Incentives ,
Self-Disclosure Requirements ,
Settlement
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
10/17/2023
/ Acquisitions ,
Anti-Corruption ,
Compliance ,
Corporate Misconduct ,
Department of Justice (DOJ) ,
Disclosure Requirements ,
Due Diligence ,
Foreign Corrupt Practices Act (FCPA) ,
Mergers ,
Safe Harbors ,
Self-Disclosure Requirements
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
10/2/2020
/ CFTC ,
Compliance ,
Criminal Penalties ,
Department of Justice (DOJ) ,
Disgorgement ,
DPA ,
FCPA Guidance ,
Foreign Corrupt Practices Act (FCPA) ,
JPMorgan Chase ,
Market Manipulation ,
Restitution ,
Securities and Exchange Commission (SEC) ,
Settlement Agreements ,
Spoofing ,
U.S. Treasury