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CSF 2.0 – An Expanded Cybersecurity Framework for all Organizations

Cybersecurity compliance, governance, and disclosure practices have evolved significantly over the past decade. As we have noted in prior blog posts, the U.S. Securities and Exchange Commission is requiring cybersecurity...more

Anti-Corruption Enforcement: 2023 Year-In-Review

As we look back on the anti-corruption enforcement trends we saw in 2023, there were several key developments. The Department of Justice (“DOJ”) brought 11 enforcement actions in 2023. Only six were against companies -...more

ComEd Settlement Proves the Foreign Corrupt Practices Act Is Not Limited to Foreign Corruption

On September 28, 2023, the Securities and Exchange Commission (“SEC”) announced that it reached a settlement with Exelon Corporation and its subsidiary, Commonwealth Edison Company (“ComEd”), relating to charges that ComEd...more

Anti-Corruption Enforcement: 2022 Year-In-Review

The following summarizes our team’s monitoring of key developments in anti-corruption enforcement during 2022 and what that may mean going forward in this new year:.....more

Cybersecurity Best Practices: Disclosure Requirements for Risk Management, Strategy, and Governance

In previous posts on the Porter Hedges Anti-Corruption & Compliance Blog, our team has discussed the U.S. Securities and Exchange Commission’s (“SEC”) proposal to amend its rules and require disclosures related to...more

Overview of New Cybersecurity Disclosure Rules for Public Companies

According to the Cybersecurity & Infrastructure Security Agency, cybersecurity is the process whereby information and communications systems, and the information contained in those systems, are protected from and/or defended...more

Increased Focus on Cybersecurity Warrants Review of Policies and Procedures

On March 9, 2022, the U.S. Securities and Exchange Commission (“SEC”) proposed amendments to its rules to require additional disclosures regarding cybersecurity risk management, strategy, governance, and incident reporting by...more

Anti-Corruption Enforcement: 2021 Year-In-Review

As we look back on 2021, several anti-corruption enforcement trends emerge. The following summarizes the key developments of the prior year and trends to watch in 2022: The Department of Justice (“DOJ”) brought 24...more

Credit Suisse Settlement Carries Broader Lessons about Reputational Risk

On October 19, 2021, the U.S. Securities and Exchange Commission (“SEC”) announced that Credit Suisse Group AG (Credit Suisse) agreed to pay $100 million to the SEC (among other penalties to other agencies) for violations of...more

World’s Largest Advertising Group Settles with SEC for $19.2 Million After Ignoring Red Flags

On September 24, 2021, the Securities and Exchange Commission (“SEC”) announced a settlement with WPP plc, the world’s largest advertising group with dual headquarters in New York City and London. According to the SEC’s...more

SEC Announces More Than $16 Million In Whistleblower Awards In August 2021

In August 2021, the Securities and Exchange Commission (the “SEC”) announced multiple sizable whistleblower awards totaling approximately $16.1 million to 14 individuals. The awards ranged from $150,000 to $3.5 million. These...more

Lack Of Sufficient Third-Party Diligence And Oversight Leads To $41 Million Penalty For Foster Wheeler

On June 25, 2021, the Department of Justice (“DOJ”) and the Securities Exchange Commission (“SEC”) simultaneously announced that the international engineering and project management firm, Amec Foster Wheeler (“Foster Wheeler”...more

FCPA: 2020 Year-In-Review

As we look back on 2020, several FCPA enforcement trends emerge. The following summarizes the key statistics and developments in 2020: •The Department of Justice (“DOJ”) brought 29 enforcement actions in 2020. 7 companies...more

Goldman Sachs Reaches Record $2.9 Billion Settlement Of Malaysia FCPA Violations

On October 22, 2020, the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) announced the coordinated $2.9 billion resolution of a Foreign Corrupt Practices Act (FCPA) enforcement action against The...more

Alert:"FCPA: 2019 Year-In-Review"

As we look back on 2019, several FCPA enforcement trends emerge. The following summarizes the key statistics and developments in 2019: The Department of Justice (“DOJ”) brought 29 enforcement actions in 2019. 12 guilty...more

Alert: "FCPA: Mid-Year Review"

With the first half of 2019 in the rearview mirror, it is a good opportunity to review the overall trends in Foreign Corrupt Practices Act (“FCPA”) enforcement actions brought by the Department of Justice (“DOJ”) and...more

Alert: "DOJ And SEC Reach Settlement With Walmart For FCPA Violations"

The Department of Justice (“DOJ”) and Securities and Exchange Commission (“SEC”) announced on June 20, 2019 that Walmart, Inc. (“Walmart”) agreed to pay a combined total of $282.7 million to resolve the years-long...more

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