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Criminal Law Antitrust & Trade Regulation

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Everything Compliance Reports from the SCCE 2017 Compliance & Ethics Institute [eBook]

by Thomas Fox on

In October 2017, nearly 2000 compliance professionals gathered in Las Vegas for the annual Society of Corporate Compliance and Ethics (SCCE) Compliance and Ethics Institute. The event was a great success for all involved, it...more

Episode 10 -- How to Conduct a Risk and Compliance Program Assessment

by Michael Volkov on

An effective ethics and compliance program requires a careful assessment of risks and existing controls. In order to design and implement an effective program, a chief compliance officer has to identify and prioritize...more

Episode 9 -- The Need for a Robust Criminal Antitrust Compliance Program

by Michael Volkov on

Global companies and corporate officers and employees face significant criminal antitrust risks.  The US Department of Justice's Antitrust Division has a mature and aggressive enforcement program targeting illegal cartel...more

FTC and Illinois AG Settle With “Phantom” Debt Collectors For $47 Million

by Goodwin on

?On November 1, the Federal Trade Commission (FTC) and Illinois Attorney General’s Office (Illinois AG) announced that they had reached a settlement to resolve a joint action brought against affiliated Chicago-based debt...more

French HOP Complaint May Test Whether Planned Obsolescence Is a Misdemeanour

by Latham & Watkins LLP on

In August 2015, the French government amended the French Energy Transition Law to include provisions rendering “planned obsolescence” a misdemeanour. In the latest wording of the provisions, article L.441-2 of the Consumer...more

Episode 8 -- The Critical Importance of Beneficial Ownership to Compliance

by Michael Volkov on

In the aftermath of the Panama Papers scandal and increased focus on shell companies and hidden ownership interests, US enforcement and regulatory agencies are increasing focus on beneficial ownership of related entities. In...more

Who Knows What Corrupt Lives in the Hearts of Men: the Telia FCPA Resolution

by Thomas Fox on

While the resolution of the Telia FCPA matter has long been awaited, the results announced in September by the Department of Justice and Securities and Exchange Commission were stunning nonetheless....more

The Perils of Compliance with the Russia Sanctions Program

by Michael Volkov on

The Ukraine-Russia Sanctions program is a complex set of executives orders, statutes and regulations defining prohibited business transactions with Russian entities and individuals. The sanctions program was instituted in...more

Podcast Episode 5 -- Tom Fox Interview

by Michael Volkov on

Corruption, Crime & Compliance is pleased to welcome Tom Fox, the Compliance Evangelist, for an interesting interview on Tom's career, his vast compliance program and writing network, and his interesting perspectives on the...more

Developments in Antitrust Capacitor Investigation: Eighth Capacitor Manufacturer Charged

by Farella Braun + Martel LLP on

On October 18, 2017, a federal grand jury sitting in San Francisco indicted capacitor manufacturer Nippon Chemi-Con for participating in a multi-decade conspiracy to fix prices for electrolytic capacitors. Nippon Chemi-Con is...more

The Halliburton FCPA Enforcement Action - Lessons for Chief Compliance Officers on Internal Controls Failures

by Thomas Fox on

One takeaway of the Halliburton-Sonangol FCPA enforcement action? Trust but verify....more

Corruption Crime and Compliance Podcast Episode 2 -- Ethics and Profits

by Michael Volkov on

With the increased focus on corporate culture, chief compliance officers have to educate the board and senior management on the inextricable link between an ethical culture and financial profitability. In this episode of...more

Corruption Crime & Compliance Episode 1 -- The Trump Administration and Enforcement

by Michael Volkov on

I am pleased to announce the new Corruption, Crime & Compliance Podcast. Episode 1 is, A Review of Trump Administration Enforcement Priorities. When the Trump Administration came into power, many commentators predicated...more

An Exploration of Soft Skills in Remediation for the Chief Compliance Officer

by Thomas Fox on

Many have focused on the more technical aspects of the remediation component of a potential Foreign Corrupt Practices Act compliance violation. I wanted to explore the soft skills that a CCO must use, both internally and...more

Lessons for Compliance Officers from Hurricane Harvey and Other Historic Weather-Related Events

by Thomas Fox on

Lessons for the corporate compliance professional from Hurricane Harvey and other weather-related disasters....more

Joint FTC / DOJ Guidance: Hurricanes Harvey and Irma

by McDermott Will & Emery on

Businesses and individuals in Texas, Florida, the Southeast, Puerto Rico and the Virgin Islands are preparing for a massive recovery and reconstruction effort in the wake of Hurricanes Harvey and Irma. The Antitrust Division...more

State Attorneys General Vigilant on Price Gouging Following Hurricanes Harvey and Irma

by Jones Day on

Many states have prohibitions on price gouging that go into effect during states of emergency. In this hurricane season, seven U.S. states and territories have declared emergencies. The Impact: Although hurricanes often...more

DOJ Prosecution of Heir Location Service Providers Dismissed on Statute of Limitations Grounds

by McDermott Will & Emery on

The US Department of Justice (DOJ) Antitrust Division’s criminal case against an heir location service provider collapsed when the US District Court for the District of Utah ruled that the government’s Sherman Act § 1 case...more

THE LATEST: Another E-Commerce Retailer Pleads Guilty in DOJ Investigation of Online Promotional Products Industry

by McDermott Will & Emery on

On August 14, 2017, we reported on an online retailer’s guilty plea for conspiring to fix the prices of “customized promotional products” such as silicone wristbands and lanyards, and the ongoing US Department of Justice...more

Judge Donato Rejects Corporate Pleas in Capacitor Cases

U.S. District Court Judge James Donato, of the Northern District of California, caught the attention of criminal antitrust litigators over the last several months with his refusal to accept the guilty pleas of three...more

DOJ's FCPA Pilot Program is Alive and Well: Two Superior Results in Declinations for Linde Gas and CDM Smith

by Thomas Fox on

Companies have a clear road map to resolve substantive FCPA violations with no criminal penalty. ...more

DOJ Obtains Price-Fixing Guilty Plea

by Jones Day on

Texas-based e-commerce company Zaappaaz, Inc.—doing business as WB Promotions, Inc., Wrist-Band.com, and Customlanyard.net—and its president both agreed to plead guilty to conspiring to fix prices for customized promotional...more

DOJ Slaps Wristband Maker With Price-Fixing Fine

by Faegre Baker Daniels on

The U.S. Department of Justice recently announced that Zaappaaz Inc., a Texas-based online retailer of customizable promotional products, and the company’s president, Azim Makanojiya, have agreed to plead guilty to conspiring...more

Everything Compliance-Episode 16, review of the book The Chickenshit Club

by Thomas Fox on

In this episode, the Everything Compliance trio of Matt Kelly, Jay Rosen and Tom Fox unpack our first book review. We consider the recently released The Chickenshit Club by Jesse Eisinger and it may mean for the compliance...more

DOJ Antitrust Corporate Dispositions May Protect Some Culpable Employees

by Jones Day on

Most companies under criminal investigation by the Antitrust Division, U.S. Department of Justice ("DOJ") eventually resolve their liability with the government short of going to trial, either by entering into a corporate...more

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