Do you think that your corporate Foreign Corrupt Practices Act (“FCPA”) settlement with the U.S. Department of Justice (“DOJ”) has given you some certainty and finality? Not so fast....more
As 2018 came to an end, a voluntary disclosure to the U.S. Department of Justice ("DOJ") and the Securities and Exchange Commission (“SEC”) by U.S.-based agribusiness, CHS, Inc. (“CHS”), of potential violations of the Foreign...more
In 2012, Donald Trump called the Foreign Corrupt Practices Act (“FCPA”) “ridiculous” and a “horrible law” that made it more difficult for U.S. companies to compete abroad. While President Trump’s private thoughts on the FCPA...more
Welcome to the spring edition of our White Collar Watch. Hopefully by the time you are reading this, winter’s storms (finally?) are behind us.
2018 has gotten off to a busy start for our practice and attorneys. We look...more
5/1/2018
/ Anti-Corruption ,
Anti-Money Laundering ,
Certiorari ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Environmental Protection Agency (EPA) ,
False Claims Act (FCA) ,
Financial Institutions ,
FinTech ,
Foreign Corrupt Practices Act (FCPA) ,
Internal Investigations ,
Lagos v United States ,
Qui Tam ,
Recordkeeping Requirements ,
SCOTUS ,
Securities and Exchange Commission (SEC)
On February 14, 2018, another major financial institution disclosed that it is under investigation for possible violations of the Foreign Corrupt Practices Act (“FCPA”). This disclosure comes at a time when the Department of...more
The U.S. Department of Justice ("DOJ") and the Securities and Exchange Commission ("SEC") issued 15 declination letters in 2017 notifying companies of their decision not to pursue charges in connection with alleged violations...more
Welcome to the summer edition of Blank Rome’s White Collar Watch. In a world that seems to bring new challenges daily—such as the global cybersecurity attacks that were launched in late June—this newsletter is designed to...more
7/25/2017
/ Anti-Bribery ,
Anti-Corruption ,
Anti-Money Laundering ,
Bribery ,
Compliance ,
Corruption ,
Criminal Investigations ,
Criminal Prosecution ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Fraud ,
Money Laundering ,
Securities and Exchange Commission (SEC) ,
White Collar Crimes
Action Item: Last week’s Supreme Court of the United States decision in Kokesh v. SEC will significantly limit the Securities and Exchange Commission’s (“SEC”) ability to collect disgorgement for violations of the Foreign...more
Any company doing business abroad is subject to the long reach of the Foreign Corrupt Practices Act (“FCPA”). Small or privately-held companies, just like large or public companies, are subject to the criminal specter of the...more
Action Item: The Securities and Exchange Commission’s enforcement action against Goodyear Tire & Rubber Company and its investigation of Mondelez International provide key lessons to U.S. companies seeking to acquire foreign...more
3/11/2015
/ Books & Records ,
Bribery ,
Corporate Counsel ,
Disgorgement ,
Due Diligence ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Entities ,
Foreign Subsidiaries ,
Goodyear ,
Internal Controls ,
Popular ,
Securities and Exchange Commission (SEC) ,
Settlement
On July 28, 2014, Smith & Wesson Holding Corp. (“Smith & Wesson”), the firearms manufacturer based in Springfield, Massachusetts, agreed to resolve charges brought by the Securities and Exchange Commission (“SEC”) for...more