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Compliance as a Valuable Tool for Avoiding Enforcement Action in Mexico and Latin America

by Morgan Lewis on

The Recent Focus on Corruption in Mexico - On July 19, 2017, the General Law of Administrative Responsibilities (GLAR) went into effect in Mexico, making it a “serious administrative offense” for individuals and companies...more

Dorsey Anti-Corruption Digest - January 2018

by Dorsey & Whitney LLP on

Keeping ahead of global anti-corruption trends is critical in today’s business markets. The Dorsey Anti-Corruption Digest, which puts global trends at your fingertips, puts you ahead. The deep experience of the Dorsey...more

Businesses face unlimited fines for failure to prevent facilitation of tax evasion

by Womble Bond Dickinson on

Introduction - As part of a global crackdown on tax evasion, the Criminal Finances Act 2017 (the Act) introduced a new offence. From 30 September 2017, an organisation commits a criminal offence if an employee or...more

Trump Administration Establishes New Sanctions Regime Targeting Human Rights Abusers - Also Expands Existing Sanctions on...

by Holland & Knight LLP on

The Trump Administration rounded out the year with two sanctions-related actions: The first involved creating a new program regarding human rights abusers and global corruption; the second involved adding several individuals...more

FCPA Digest - January 2018

by Shearman & Sterling LLP on

Shearman & Sterling’s bi-annual Trends & Patterns in FCPA Enforcement report provides insightful analysis of recent enforcement trends and patterns in the US, the UK and elsewhere, as well as helpful guidance on emerging best...more

Trump Administration Announces Sanctions Pursuant to the Global Magnitsky Act

On December 21, 2017, the Trump Administration released a list of foreign nationals it has identified to be sanctioned in accordance with the Global Magnitsky Human Rights Accountability Act of 2016. In December 2016, we...more

Top Ten International Anti-Corruption Developments for November 2017

by Morrison & Foerster LLP on

In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international anti-corruption developments from the past month, with links to primary...more

New FCPA Corporate Enforcement Policy Incentivizes Corporate Voluntary Self-Disclosure and Cooperation

Under the new FCPA Corporate Enforcement Policy recently released by the Department of Justice (“DOJ”), when a company has voluntarily self-disclosed misconduct, fully cooperated in the government’s ensuing investigation, and...more

The Sapin II Act: New Perspectives on Cross-Border Investigations

On November 30, 2017, the Institut des Hautes Etudes sur la Justice (IHEJ) and Skadden hosted a roundtable at the Cercle de l’Union Interalliée in Paris to discuss new perspectives on the Sapin II Act and cross-border...more

The Criminal Finances Act of 2017: New Compliance Requirements for UK Businesses

by Blank Rome LLP on

On April 27, 2017, the United Kingdom enacted the Criminal Finances Act 2017 (the "Act"), which provides that companies and partnerships ("relevant bodies") are criminally liable if they fail to implement adequate procedures...more

The Wisdom (and Challenge) of a Global Anti-Bribery Policy

by NAVEX Global on

Don’t look now, but anti-bribery laws are breaking out all over the place. In Europe, new laws either have come into effect, or will come into effect within 12 months, in France, Italy, and Ireland; Britain, of course, has...more

Corporate Law & Governance Update - December 2017

by McDermott Will & Emery on

Unprecedented 2018 Board Challenges - The health system board should be prepared to address an extraordinary number of significant, enterprise-level challenges that are expected to arise in 2018. These challenges will...more

Dorsey Anti-Corruption Digest - December 2017

by Dorsey & Whitney LLP on

Deputy Attorney General Rod Rosenstein announced the addition of a new Department of Justice (DOJ) Foreign Corrupt Practices Act (FCPA) policy, titled the FCPA Corporate Enforcement Policy. The new policy, which was...more

DOJ Announces New FCPA Policy to Further Incentivize Corporate Voluntary Self-Disclosure and Cooperation

by Foley Hoag LLP on

The U.S. Foreign Corrupt Practices Act turned forty this year. The Department of Justice is marking that anniversary by announcing a new Corporate Enforcement Policy specific to FCPA matters. The new Policy makes explicit...more

Overseas investment by Chinese enterprises should pay attention to the risk of the U.S. Foreign Corrupt Practices Act

by Morgan Lewis on

With the deepening of global economic integration, more and more Chinese enterprises go abroad to participate in local investment and economic construction. Among them, as an important part of the national economy, Chinese...more

US Department of Justice Refines Incentives for Corporate Disclosure of Potential FCPA Violations

by Dechert LLP on

Speaking at a conference in Maryland on November 29, 2017, Deputy Attorney General Rod Rosenstein announced a revised Foreign Corrupt Practices Act (“FCPA”) Corporate Enforcement Policy (“CEP”). This policy builds on the...more

Building on Pilot Program, DOJ Announces New FCPA Corporate Enforcement Policy

by Morrison & Foerster LLP on

On November 29, 2017, Deputy Attorney General Rod Rosenstein announced a new “FCPA Corporate Enforcement Policy” (“Policy”) that extends and revises the FCPA Pilot Program. In his announcement, DAG Rosenstein explained that...more

Cross-Border Investigations Update - November 2017

This issue of Skadden’s semiannual Cross-Border Investigations Update takes a close look at recent cases, regulatory activity and other key developments, including new U.K. reporting obligations for sanctions violations,...more

DOJ Announces Revised FCPA Corporate Enforcement Policy

In a speech yesterday at the 34th International Conference on the Foreign Corrupt Practices Act, U.S. Deputy Attorney General Rod Rosenstein announced the Department of Justice’s (DOJ) revised Foreign Corrupt Practices Act...more

Top Ten International Anti-Corruption Developments for October 2017

by Morrison & Foerster LLP on

In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international anti-corruption developments from the past month, with links to primary...more

DOJ Makes Major Move to Expand Leniency for Companies That Disclose Foreign Bribery

by Morgan Lewis on

The department laid out a bold new policy providing “presumption” of non-prosecution for companies that self-report FCPA violations and meet other conditions....more

7 Key Takeaways: Bribery & The Boardroom

Kilpatrick Townsend Partner Joe Dowdy recently gave a presentation at the Charlotte Chapter of the Association of Corporate Counsel that addressed the enforcement of high-profile federal criminal laws rooted in bribery,...more

Anti-Bribery Compliance Meets Permits, Approvals and Licences in India

by Foley & Lardner LLP on

Obtaining permissions, approvals and licences in India creates high risks for bribery on account of there being significant interaction between the company and government authorities. Originally published by IBA...more

Corporate Investigations and White Collar Defense - November 2017

Insider Trading: Once More Into the Breach - Why it matters: On Aug. 23, 2017, the Second Circuit decided U.S. v. Martoma, in which the court affirmed a tippee’s conviction in an insider trading case based on the Supreme...more

SEC Enforcement: Another Look At Last Fiscal Year

by Dorsey & Whitney LLP on

The SEC published its statistics for the last fiscal year in a glossy report centered on a discussion of the new retail/cyber focus of the Enforcement Division. Statistics are not the sole measure of success the agency...more

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