News & Analysis as of

Anti-Bribery State-Owned Enterprises

Thomas Fox - Compliance Evangelist

J&F – The SEC Order

Today, I continue a multi-part exploration of one world’s largest anti-corruption enforcement actions, the J&F Investimentos SA (J&F) matter. It involved huge fines and penalties in both Brazil and the United States. Of...more

Thomas Fox - Compliance Evangelist

Farewell to Eddie Van Halen and Joint Venture Risks Under the FCPA

Eddie Van Halen died yesterday. He is the first rocker, more or less, of my generation to die after the age of 60. He was also one of the greatest guitarists ever. Indeed, I would rank him as the best guitarist of his...more

Thomas Fox - Compliance Evangelist

Sargeant Marine – The Individual Guilty Pleas

We rarely have seen a single Foreign Corrupt Practices Act (FCPA) enforcement action generate so many individual criminal pleas. The Sargeant Marine Inc. (Sargeant Marine) case is an exception. To date, there have been six...more

Thomas Fox - Compliance Evangelist

Tribute to Gale Sayers and Criminal FCPA Plea by Sargeant Marine

Gale Sayers died Wednesday. For any serious student of the National Football League (NFL), Sayers will always be known as one of the greatest runners of all-time. His rookie season was one for the record books; scoring 22...more

A&O Shearman

DOJ Issues FCPA Opinion Procedure Approving Legitimate Payments To Government Instrumentalities

A&O Shearman on

On August 14, 2020, the U.S. Department of Justice (“DOJ”) released its first Foreign Corrupt Practices Act (“FCPA”) Opinion (the “August 14 Opinion”) in six years, in response to a request from a multinational company...more

Sheppard Mullin Richter & Hampton LLP

U.S. Targets Private Equity Funds for FCPA Scrutiny

The private equity industry is facing increased scrutiny by the U.S. Government for potential violations of the Foreign Corrupt Practices Act (“FCPA”). The Securities and Exchange Commission (“SEC”) has created a new private...more

BakerHostetler

Foreign Corrupt Practices Act 2015 Update

BakerHostetler on

Despite a decline in enforcement actions by the Securities Exchange Commission (“SEC”) and the Department of Justice (“DOJ”), the first half of 2015 has continued to highlight the relevance and ever-evolving effects of the...more

Morrison & Foerster LLP

Canada’s New Extractive Sector Transparency Measures Act and its Implications for Companies Subject to the U.S. Foreign Corrupt...

On June 1, 2015, Canada’s Extractive Sector Transparency Measures Act (“ESTMA” or “the Act”) came into force. Approved in December 2014, but not in force until this month, the Act requires companies in the extractive sector...more

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