As Tom and Jay prepare for the December holiday season, they consider the DOJ/SEC’s strong affirmation that aggressive FCPA enforcement is here to stay, changes to the Yates Memo/plea for increased cooperation, and some of the week’s other top compliance and ethics stories.
1. DOJ/SEC reaffirm importance of FCPA prosecutions. Christopher Cole reports on regulators' remarks at ACI National FCPA Conference in Law360. Going in another direction, Deputy Attorney General John Cronan discusses the See more +
As Tom and Jay prepare for the December holiday season, they consider the DOJ/SEC’s strong affirmation that aggressive FCPA enforcement is here to stay, changes to the Yates Memo/plea for increased cooperation, and some of the week’s other top compliance and ethics stories.
1. DOJ/SEC reaffirm importance of FCPA prosecutions. Christopher Cole reports on regulators' remarks at ACI National FCPA Conference in Law360. Going in another direction, Deputy Attorney General John Cronan discusses the importance of the public private partnership in fighting bribery and corruption. Finally, Rod Rosenstein announces cutbacks to the Yates Memo in a speech. Matt Kelly reports on his speech on Radical Compliance. For full text of speech, see here.
2. Facebook woes continue as a cache of its internal documents end up in Britain’s House of Commons immediately before a hearing. Adam Satariano reports in The New York Times. The hearing is held with an empty chair for Mark Zuckerberg, who was too busy to drop by. Tom and Jonathan Armstrong have their first emergency podcast on Life with GDPR to explain it all.
3. How do you establish pace and scope in an SEC investigation? Dan Portnov explains in Grand Jury Target.
4. FIFA Judge Balks At $116M Restitution Bids In Bribery Case. Stewart Bishop reports in Law360.
5. Russia’s largest telecom company, MTS, reserves $840MM for FCPA resolution. Harry Cassin reports in the FCPA Blog.
6. Former Venezuelan National Treasurer Alejandro Andrade is sentenced to 10 years in prison for money laundering in accepting over $1bn in bribes. Harry Cassin reports in the FCPA Blog. Sam Rubenfeld reports in the WSJ Risk & Compliance Journal.
7. What is the role of the human element in internal controls? Tom Gorman explores this interesting issue in SEC Actions.
8. 11 Latin American law firms join forces to create a template for best practices in an anti-corruption investigation. Melissa Van Brunnersum reports.
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