News & Analysis as of

Board of Directors Securities and Exchange Commission (SEC) Foreign Corrupt Practices Act (FCPA)

American Conference Institute (ACI)

[Event] Global Anti-Corruption, Ethics & Compliance - June 10th - 11th, New York, NY

ACI's Global Anti-Corruption, Ethics & Compliance – New York is your best opportunity to hear how companies are addressing the status of DOJ and SEC priorities, effective compliance and risk strategies, strengthening...more

Guidepost Solutions LLC

With Enforcement Actions Likely to Increase in 2022, Companies Should Ask Where the Bodies are Buried

In 2022, companies are likely to see an increase in white collar and regulatory investigations and enforcement actions. Here are just a few reasons why this is likely to happen. First, in the late fall, Deputy Attorney...more

Thomas Fox - Compliance Evangelist

The Herbalife FCPA Enforcement Action: Part 4 – Final Thoughts

We are the end of my multi-part exploration of the Herbalife Nutrition Ltd (Herbalife) Foreign Corrupt Practices Act (FCPA) enforcement action with both the Department of Justice (DOJ) and Securities and Exchange Commission...more

Thomas Fox - Compliance Evangelist

Why the Board of Directors Need an Investigation Protocol

Many companies have an investigation protocol in place when a potential compliance or other legal issue arises. However, many Boards of Directors do not have the same rigor when it comes to an investigation, which should be...more

Thomas Fox - Compliance Evangelist

Prudent discharge of compliance obligations by a Board

What are the obligations of a Board member regarding the Foreign Corrupt Practices Act (FCPA)? Are the obligations of the Compliance Committee under the FCPA at odds with a director’s “prudent discharge of duties to...more

Jones Day

Corporate Anticorruption Compliance Programs: Ten Questions Every Board Director Should Ask

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The United States Department of Justice, the U.S. Securities and Exchange Commission, and non-U.S. governments and agencies have recently emphasized their continued commitments to pursuing both corporate and individual...more

Patterson Belknap Webb & Tyler LLP

Commercial Division Dismisses Derivative Lawsuit After Board Rejects Shareholder Demand

The decision to bring a lawsuit on behalf of a corporation is entrusted to the corporation’s board of directors. A shareholder may not maintain a derivative lawsuit on behalf of a corporation without first making a demand on...more

Thomas Fox - Compliance Evangelist

The Telia FCPA Resolution: Part V-Lessons Learned

Today, lessons learned. Over the past several blog posts, I have taken a deep dive into the Telia Company AB (Telia) Foreign Corrupt Practices Act (FCPA) enforcement action. Anytime you have new No. 1 in the all-time FCPA...more

Sheppard Mullin Richter & Hampton LLP

Under Delaware Law, the Occurrence of Alleged Illegal Conduct at a Company Is Not Enough to Plead Demand Futility Sufficient to...

In a shareholder derivative action, to survive a motion to dismiss for failure to plead facts showing demand futility, a derivative plaintiff must plead particularized facts showing either actual involvement by a majority of...more

A&O Shearman

Delaware Chancery Court Dismisses Caremark Claim For Failure To Adequately Allege That The Board Consciously Disregarded FCPA...

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On June 16, 2017, Vice Chancellor Tamika Montgomery-Reeves of the Delaware Court of Chancery dismissed breach of fiduciary duty and other claims brought derivatively against the directors and former chief financial officer of...more

Thomas Fox - Compliance Evangelist

Day 7 of One Month to Better Investigations and Report-How Investigations Inform Remediation

There is nothing like an internal whistleblower report about a FCPA violation, the finding of such an issue or (even worse) a subpoena from the DOJ to trigger the Board of Directors and senior management attention to the...more

Thomas Fox - Compliance Evangelist

Day 5 of One Month to Better Investigations and Reporting-the Board’s Investigation Protocol

Many companies have an investigation protocol in place when a potential Foreign Corruption Practices Act (FCPA) or other legal issue arises? However, many Boards of Directors do not have the same rigor when it comes to an...more

Thomas Fox - Compliance Evangelist

This Week in FCPA-Episode 55, the Covfefe Edition

This week, Jay and I have a wide-ranging discussion on some of the week’s top compliance related stories. We discuss: 1. Brazilian meatpacker JBS agrees to the largest fine ever for fine for bribery and corruption, $3.2bn...more

Jones Day

Department of Justice Fraud Section Provides Guidance on Evaluating Corporate Compliance Programs

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On February 8, 2017, the United States Department of Justice ("DOJ") Fraud Section published a blueprint for assessing corporate compliance efforts, titled "Evaluation of Corporate Compliance Programs" ("Guidance"). It...more

The Volkov Law Group

C-Suite Misconduct Results in Sociedad Quimica Y Minera FCPA Resolution with DOJ and SEC

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In an unusual FCPA enforcement action, the Justice Department and the SEC resolved FCPA violations against Sociedad Quimica y Minera, a Chilean chemical and mining company, for a total of $30.5 million, for paying...more

Thomas Fox - Compliance Evangelist

Compliance Expertise Needed on the Board

This week I have been exploring the different types compliance committee’s which an organization can utilize to help effect a best practices compliance program. I have written about compliance committee’s at the Board of...more

Thomas Fox - Compliance Evangelist

Forecasting, Risk Management and Compliance

When I was in the corporate world, I cannot begin to recall the number of times senior management had an overly optimistic forecast regarding some transaction; whether the transaction was the purchase of a smaller company, a...more

Robins Kaplan LLP

Your daily dose of financial news The Brief – 3.24.16

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In a move that will surprise no regular reader here, Starboard Value has announced plans to put up its own slate of directors for Yahoo in an attempt to oust its “entire incumbent board” – NYTimes and WSJ... The Deal...more

Porter Hedges LLP

Business Litigation Alert: "Court Ruling Allows Whistleblower to Sue Board Members"

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A recent ruling in California federal court (here) broadens legal protections for whistleblowers and expands who can be held liable in retaliation cases. In the case, Wadler v. Bio-Rad Labs., Inc., a federal judge ruled that...more

Thomas Fox - Compliance Evangelist

VW Emissions Testing Scandal – View from the Board

The Board of Directors role in the Volkswagen (VW) emissions test scandal is one that is only now being scrutinized. In an article in the New York Times (NYT), entitled “Problems at VW Start at the Boardroom”, James B....more

The Volkov Law Group

3 Ways to Improve Compliance Training

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As the compliance profession matures and evolves, the elements of an effective compliance program follow a similar pattern. Compliance training programs have become more sophisticated over the last five years, as...more

The Volkov Law Group

Corporate Board Oversight Responsibilities And Liability

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The Department of Justice is targeting individuals for criminal FCPA violations. As I have discussed before, DOJ is bringing strong cases with overwhelming evidence against individual defendants. ...more

Thomas Fox - Compliance Evangelist

What Is Board Responsibility For Compliance?

The nightmare of every corporate director is to wake up to find out that the company of the Board he or she sits on is on the front page of the New York Times (NYT) for alleged illegal conduct. Originally Published in...more

Thomas Fox - Compliance Evangelist

Board Responsibility Under The FCPA – A Herculean Task?

The nightmare of every corporate director is to wake up to find out that the company of the Board he or she sits on is on the front page of a national newspaper for alleged illegal conduct. ...more

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