For busy in-house counsel and compliance professionals, we have tried to summarize the most important international anti-corruption developments in the past month with links to primary resources. November was definitely a busy month with a variety of developments. Here is our Top Ten list:

1. Bio-Rad $55 Million FCPA Resolution. On November 3, 2014, DOJ and SEC simultaneously announced resolutions with Bio-Rad Laboratories. DOJ entered into a two-year non-prosecution agreement (NPA) with Bio-Rad arising from conduct in Russia. The NPA included a monetary penalty of $14.35 million and self-reporting obligations regarding Bio-Rad’s continuing implementation of an enhanced compliance program (i.e., no corporate monitor). SEC entered into a cease and desist order against Bio-Rad in which the company agreed to pay $40.7 million in disgorgement and prejudgment interest in connection with the company’s sales in Russia, as well as in Thailand and Vietnam. Continuing to add to the debate about voluntary disclosure, the matter was voluntary disclosed by Bio-Rad more than four years ago and cost the company $55 million, exclusive of attorneys’ and consultants’ fees...