News & Analysis as of

Airlines Enforcement Actions Foreign Corrupt Practices Act (FCPA)

Thomas Fox - Compliance Evangelist

The FCPA Corporate Enforcement Policy in Action-Part II

How should a compliance practitioner use the information from these three Foreign Corrupt Practices Act (FCPA) enforcement actions going forward? Do the differing results in these three enforcement actions (Dun & Bradstreet...more

Thomas Fox - Compliance Evangelist

The FCPA Corporate Enforcement Policy in Action-Part I

We had three major Foreign Corrupt Practices Act (FCPA) cases resolved in Q2 2018. They all reached different resolutions under the new FCPA Corporate Enforcement Policy and the new anti-piling on policy....more

Skadden, Arps, Slate, Meagher & Flom LLP

"Cross-Border Investigations Update - December 2016"

This issue of Skadden’s semiannual Cross-Border Investigations Update looks at Brexit’s impact on corporate crime and investigations, the U.S. DOJ’s increased use of forfeiture actions with international implications, current...more

Cadwalader, Wickersham & Taft LLP

United Airlines Settles with SEC for Side-Stepping Its Own Anti-Corruption Controls: Management Override for a Ride Over to South...

In a settlement highlighting the need for public companies to implement – and adhere to – effective internal controls, United Airlines “United” recently paid a $2.4 million civil penalty to the Securities and Exchange...more

Thomas Fox - Compliance Evangelist

The Chairman’s Flight and the US Corrupt Practices Act

Earlier this week a most interesting non-Foreign Corrupt Practices Act (FCPA) bribery and corruption enforcement, actions was announced by the Securities and Exchange Commission (SEC). It involved a clear quid pro quo benefit...more

The Volkov Law Group

DOJ and SEC Collect $22 Million from LAN Airlines for Conduct in Resolving Labor Dispute

The Volkov Law Group on

Last week, the Justice Department and the SEC announced parallel FCPA settlements totaling $22 million in fines, penalties and disgorgement against LAN Airlines, a Chile-based airline, for conduct in resolving a labor dispute...more

Thomas Fox - Compliance Evangelist

LATAM/LAN FCPA Enforcement Action, Part I-Some Questions

What is the cost of a Foreign Corrupt Practices Act (FCPA) violation? One subset of that question is what is the cost of not cooperating and not remediating during the pendency of such investigations? Those were two of the...more

Thomas Fox - Compliance Evangelist

The End of an Era and the End of Facilitation Payments?

Two famous New Yorkers died this week. Both spoke to not only to the glamour of the Big Apple, but the city’s once undisputed crown as the cultural mecca of the US. They were Allie Sherman and Bess Myerson....more

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