News & Analysis as of

Bribery Dept. of Justice

This Week in FCPA-Episode 77, the Home for the Holidays Edition

by Thomas Fox on

Jay and I return for a wide-ranging discussion on some of the top compliance and ethics related stories of the week, including: 1. The DOJ/SEC FCPA Guidance turned 5 years old this week. For the compliance practitioner,...more

Charges Unsealed Against Five Individuals, Including Two Executives, In Foreign Bribery Scheme Involving Rolls-Royce

by Shearman & Sterling LLP on

On November 7, 2017, the Department of Justice (“DOJ”) unsealed charges against five individuals—including two executives—alleging violations of the Foreign Corrupt Practices Act (“FCPA”) in connection with an alleged foreign...more

The FCPA Week That Was — Seven Individuals Charged for FCPA Violations

by Michael Volkov on

To all the “nattering nabobs of negativity” concerning FCPA enforcement, the US Justice Department responded with a resounding message – not only is FCPA enforcement here to stay, but individual violators are on DOJ’s radar...more

DOJ – Aggressive International Anti-Corruption Enforcement to Continue

by Thomas Fox on

Acting Assistant Attorney General Ken Blanco spoke yesterday at FCPA/OECD Anniversary Conference at the NYU School of Law. His remarks made clear not only the importance of enforcement of laws against bribery and corruption...more

Rolls Royce in America – Four Guilty Pleas and an Indictment

by Thomas Fox on

For those who might have wondered if the Sessions Justice Department (DOJ) was going to enforce the Foreign Corrupt Practices Act (FCPA), that question seems to have been answered in the affirmative. In September, the DOJ and...more

Breaking Down Telia: One of the Largest FCPA Settlements and the First of the Trump Administration

The recent settlement by Telia Company AB (“Telia”), the first of the U.S. Department of Justice (“DOJ”) under the Trump administration and one of the largest FCPA enforcement actions to date, has been touted by some as a...more

Red Notice Newsletter - October 2017

ANTICORRUPTION DEVELOPMENTS – Global Compliance Overhaul for SAP as DOJ and SEC Investigate Payments Allegedly Related to South African Government Contracts – On October 26, 2017, German software company SAP SE...more

Top Ten International Anti-Corruption Developments for September 2017

by Morrison & Foerster LLP on

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

Who Knows What Corrupt Lives in the Hearts of Men: the Telia FCPA Resolution

by Thomas Fox on

While the resolution of the Telia FCPA matter has long been awaited, the results announced in September by the Department of Justice and Securities and Exchange Commission were stunning nonetheless....more

The Halliburton FCPA Enforcement Action - Lessons for Chief Compliance Officers on Internal Controls Failures

by Thomas Fox on

One takeaway of the Halliburton-Sonangol FCPA enforcement action? Trust but verify....more

Red Notice Newsletter - Chinese

ANTICORRUPTION DEVELOPMENTS - Alere Inc. Agrees to Pay More Than $13 Million to Resolve SEC FCPA Enforcement Action - On September 28, 2017, Alere Inc. (“Alere”), a Massachusetts based manufacturer of medical diagnostic...more

Red Notice Newsletter - Russian

ANTICORRUPTION DEVELOPMENTS - Alere Inc. Agrees to Pay More Than $13 Million to Resolve SEC FCPA Enforcement Action - On September 28, 2017, Alere Inc. (“Alere”), a Massachusetts based manufacturer of medical diagnostic...more

Red Notice Newsletter - September 2017

ANTICORRUPTION DEVELOPMENTS - Alere Inc. Agrees to Pay More Than $13 Million to Resolve SEC FCPA Enforcement Action - On September 28, 2017, Alere Inc. (“Alere”), a Massachusetts based manufacturer of medical...more

Where O’ Where Did Our Monitors Go? — The Telia Bribery Case

by Michael Volkov on

Just when everyone was anticipating the beginning of an uptick in FCPA enforcement in 2017, the Justice Department and the SEC delivered a resounding message to remind everyone that FCPA enforcement is here to stay. However,...more

The Fraud Triangle, Rationalizations and Compliance Programs

by Thomas Fox on

The fraud triangle is well-known to most compliance practitioners. Its third sides are pressure, opportunity and rationalization. When these three factors converge, there is danger of an ethical lapse which could lead to...more

Tribute To Gogos – New Corruption Scandal In College Sports

by Thomas Fox on

October is my annual Classic Monster Movie month tribute. I recognize it is not yet October but I wanted to begin a bit early this year as September saw the passing of Basil Gogos. He was the prime illustrator for the...more

The Telia FCPA Resolution: Part V-Lessons Learned

by Thomas Fox on

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

Telia FCPA Enforcement Action: Part IV – Getting Some Monies Back

by Thomas Fox on

I have spent the past few blog posts reviewing the many lessons that can be garnered by the compliance practitioner from the Telia Company AB (Telia) Foreign Corrupt Practices Act (FCPA) resolution. However, there is one...more

The Telia FCPA Resolution: Part III – The Individuals

by Thomas Fox on

I continue my exploration of the Telia Company AB (Telia) Foreign Corrupt Practices Act (FCPA) enforcement action and the parallel actions. Today I will consider the individuals who have been criminally indicted in Sweden and...more

DOJ And SEC Bring Major FCPA Enforcement Actions Against Swedish Telecom Firm, Imposing One Of Largest FCPA Penalties In History

by Shearman & Sterling LLP on

On September 21, 2017, the Department of Justice (“DOJ”) and Securities and Exchange Commission (“SEC”) announced significant enforcement actions against Telia Company AB, a Swedish telecommunications firm, for alleged...more

Top Ten International Anti-Corruption Developments for August 2017

by Morrison & Foerster LLP on

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

In the Third-Largest FCPA Enforcement Action Ever, Telia Agrees to Pay Almost $1 Billion to Resolve Bribery Inquiry in Uzbekistan;...

by Ropes & Gray LLP on

In the first blockbuster FCPA action of the Trump administration, on September 21, 2017, Swedish telecommunications company Telia agreed to pay $965 million in total penalties to the U.S. Department of Justice (“DOJ”) and...more

The Telia FCPA Resolution: Part II – The Bribery Schemes

by Thomas Fox on

Over the next few blog posts, I will be exploring the resolution and what lessons the compliance practitioner can draw from the Telia Company Foreign Corrupt Practices Act, (FCPA) enforcement action, the parallel actions and...more

The Telia FCPA Resolution, Part I

by Thomas Fox on

While the resolution of the Telia Company (Telia) Foreign Corrupt Practices Act (FCPA) matter has long been awaited, the results announced yesterday by the Department of Justice (DOJ) and Securities and Exchange Commission...more

Book Review: The Chickenshit Club

by Thomas Fox on

To my mind the most significant and important book that every Chief Compliance Officer (CCO), General Counsel (GC) and compliance practitioner needs to read is The Chickenshit Club by Pulitzer Prize winning journalist Jesse...more

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