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Bribery CEOs

Society of Corporate Compliance and Ethics...

The CCO departure bonus: A revolutionary tool for ethical corporate governance

Sarah Chen, the newly appointed chief compliance officer (CCO) at Granite Oil Corp, sat across from the board of directors, her heart racing. The company was on the brink of closing a lucrative deal in an emerging market, but...more

Thomas Fox - Compliance Evangelist

Operationalizing Compliance: Part 4-Effectiveness, Redux

Welcome to a special five-part podcast series on Operationalizing Your Compliance Program, sponsored by Broadcat LLC. Over this series, I visit with Jennifer May, Director of Compliance Advisory; Taylor Edwards, Director of...more

Paul Hastings LLP

Sign on the Dotted Line: Compliance Certifications by CEOs and CCOs A Likely Requirement

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As it continues its focus not just on enforcement, but on compliance, members of the U.S. Department of Justice have foreshadowed a sea change for Chief Executive Officers and Chief Compliance Officers in corporate...more

McGuireWoods LLP

The Perils of Global Expansion: World’s Largest Ad Agency Sanctioned $19 Million for FCPA Violations, Insufficient Controls

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Global expansion without adequate controls is asking for trouble. That’s the lesson of a $19 million settlement between WPP, the world’s largest advertising agency, and the U.S. Securities and Exchange Commission (SEC) to...more

Porter Hedges LLP

World’s Largest Advertising Group Settles with SEC for $19.2 Million After Ignoring Red Flags

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On September 24, 2021, the Securities and Exchange Commission (“SEC”) announced a settlement with WPP plc, the world’s largest advertising group with dual headquarters in New York City and London. According to the SEC’s...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments For April 2021

In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international anti-corruption developments from the past month, with links to primary...more

Robins Kaplan LLP

Financial Daily Dose 3.6.2020 | Top Story: Volatility Reigns as Stocks Dive Over Continued COVID-19 Fears

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Volatility’s the name of the game again, folks, and we have COVID-19 to thank. Just a day after markets jumped in response to central bank and Super Tuesday news, the dove again some 3% as virus-related fears took hold again....more

Robins Kaplan LLP

Financial Daily Dose 2.27.2020 | Top Story: Ninth Circuit Limits First Amendment Application on Tech Platforms

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The Ninth Circuit has ruled unanimously that privately operated internet platforms are “free to censor content they don’t like”—a “not unexpected” ruling that nonetheless “marks the most emphatic rejection . . . that YouTube,...more

The Volkov Law Group

Ericsson’s Pervasive Bribery Conduct: The Toxic Mix of Senior Executive Involvement and Third Party Corruption (Part II of II)

The Volkov Law Group on

Ericsson’s FCPA settlement is in the books (not the books and records).  But it casts a significant shadow across the FCPA landscape.  A pervasive and systemic culture of bribery is defined to reflect senior executive...more

Robins Kaplan LLP

Financial Daily Dose 12.06.2019 | Top Story: Aramco Prices Shares at High-end of Range That Would Value Company at $1.7 trillion

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Saudi Aramco has priced its offering at the high end of its range, setting the company up to raise more than $25 billion and value the company at nearly $1.7 trillion—all part of what promises to make this the world’s biggest...more

The Volkov Law Group

Episode 117 -- FCPA Update: Samsung FCPA Settlement; Braskem Former CEO Indicted; Transport CEO Convicted after Trial

The Volkov Law Group on

The Justice Department has been very busy in FCPA enforcement matters -- (1) Samsung Heavy Industries paid $75 million to settle FCPA violations; (2) Braskem's former CEO was indicted on FCPA charges; and (3) after a...more

Robins Kaplan LLP

Financial Daily Dose 11.21.2019 | Top Story: UAW President Resigns After GM Accuses Fiat Chrysler of Bribery

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More than a bit of drama in the auto world yesterday, with General Motors suing rival Fiat Chrysler, accusing it of “bribing United Auto Workers officials to gain competitive advantages in contract negotiations.”  The UAW’s...more

Thomas Fox - Compliance Evangelist

Westport Fuel Systems – Control Fraud at Its Finest

Today, I conclude my short exploration of the recent spate of Foreign Corrupt Practices Act (FCPA) enforcement actions brought by the Securities and Exchange Commission (SEC) at the close of its fiscal year. Each FCPA...more

Foley & Lardner LLP

The Twelve Compliance Steps Every Multinational Corporation Should Undertake in Light of Recent Trump Administration Enforcement...

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Over the last month, regulators with the Trump administration sent a loud message to companies subject to U.S. jurisdiction: Enforcement of laws governing international activities is alive and well and the laws will continue...more

Thomas Fox - Compliance Evangelist

When Will Shareholders Force Boards to Do Compliance?

Today we honor one of the most iconic moments of World War II (WWII) and one of the most famous photographs of all time, that of the Marines raising the US flag on Mount Suribachi on the island of Iwo Jima. Marine...more

Dechert LLP

FCPA Enforcement Action Highlights Risks for the Financial Services Industry and Individual Executives

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New York-based hedge fund Och-Ziff Capital Management Group (the “Hedge Fund”) agreed to pay approximately $412 million to resolve charges brought by the U.S. Securities and Exchange Commission (“SEC”) and Department of...more

The Volkov Law Group

5 Signs Your Anti-Corruption Compliance Program is Suffering from “Tunnel Vision”

The Volkov Law Group on

Many companies, depending on the industry, have implemented anti-corruption compliance programs. Some of the programs meet the standard for an “effective” anti-corruption compliance program. There is a vast difference between...more

Thomas Fox - Compliance Evangelist

Bone-headed Moves on the Football Field and Idiotic Statements About Corruption

That football truism (allegedly) came from former Texas Longhorn head coach Darrell Royal. While he intoned it in a different era, Pete Carroll and his Seattle Seahawks proved it still to be valid in the most recent Super...more

Akin Gump Strauss Hauer & Feld LLP

Recorded Conversations with In-House Counsel Permitted as Evidence in FCPA Trial

Earlier this month, a federal judge in New Jersey held that a secretly recorded conversation between a former chief executive officer and his general counsel may be used by prosecutors as evidence against the former executive...more

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