Daily Compliance News: April 8, 2025, The End of Monitors Edition
10 For 10: Top Compliance Stories For The Week Ending April 5, 2025
2 Gurus Talk Compliance: Episode 48 – The March Madness Edition
10 For 10: Top Compliance Stories For The Week Ending, March 22, 2025
Regulatory Ramblings: Episode 65 – The Trump Administration’s Decision to Halt FCPA Enforcement – The Implications for Asia and the World with Tom Fox, Malcolm Nance, and Philip Rohlik
Daily Compliance News: March 19, 2025, The Why CISOs Quit Edition
10 For 10: Top Compliance Stories For the Week Ending March 15, 2025
Episode 356 -- Trump Administration Hits Pause on FCPA Enforcement
Episode 351 -- Deep Dive into the AAR FCPA Settlement
Episode 350 -- Deep Dive into McKinsey FCPA Case
Corruption, Crime & Compliance: BIT Mining Resolves FCPA Case for $10 Million and CEO Pan Indicted
Episode 349 -- Review of the BIT Mining FCPA Settlement
Episode 345 -- Raytheon Pays $950 Million to Resolve Fraud, FCPA, ITAR and False Claims Act Violations
Episode 344 -- SEC Settles FCPA Case with Moog for $1.7 Million
Episode 339: Four Sanctions Cases Everyone Should Know
Episode 338 -- Deep Dive into the Deere SEC FCPA Case
Wicked Coin: The "Fat Leonard" Scandal
Corruption, Crime & Compliance: Deep Dive into The Gunvor FCPA Settlement
Episode 307 -- Sanctions Enforcement Review and Predictions for 2024
Episode 300 -- Deep Dive into DOJ FCPA Settlement with Two U.K. Reinsurance Companies for Bribery in Ecuador
2024 saw another strong year of Foreign Corruption Practices Act (FCPA) enforcement actions from the United States Department of Justice (DOJ) and the Securities and Exchange Commission (SEC). There were 15 resolutions with...more
I had many ideas for an article that would expand on recent developments in the compliance and ethics space. My working title was the creatively light “Recent Developments.” But after meeting with SCCE & HCCA’s editorial...more
The SEC notched another FCPA settlement, continuing its steady pursuit and resolution of FCPA cases. In the meantime, the Justice Department has been silent in the FCPA enforcement arena. In this episode of Corruption,...more
The U.S. Securities and Exchange Commission (“SEC”) recently instituted proceedings against Deere & Company (“John Deere”), a leading global manufacturer of agricultural and heavy machinery, for multiple violations of the...more
Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption law and enforcement developments from the past...more
Albemarle Corporation (Albemarle), recently agreed to pay more than $218 million to resolve investigations by the U.S. Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) into violations of the...more
On September 28, 2023, the Securities and Exchange Commission (“SEC”) announced that it reached a settlement with Exelon Corporation and its subsidiary, Commonwealth Edison Company (“ComEd”), relating to charges that ComEd...more
Koninklijke Philips N.V., a global medical technology manufacturer, recently agreed to pay over $62 million to resolve a Foreign Corrupt Practices Act (FCPA) enforcement action with the Securities and Exchange Commission...more
Here are some basic propositions that surround FCPA compliance. It is often underplayed that the FCPA contains more than just a bribery prohibition – the FCPA contains broad provisions, requiring accurate books and records...more
In this post, we conclude our exploration of the Foreign Corrupt Practices Act (FCPA) enforcement action involving the now recidivist Oracle Corporation. This enforcement action was concluded with the Securities and Exchange...more
Oracle’s SEC settlement for $23 million underscores the power of the FCPA provisions mandating effective internal controls and accurate books and records. As everyone knows, these provisions can be applied to a wide-range of...more
GOL’s bribery schemes present some interesting lessons. Interestingly, at the center of the bribery scheme was a member of GOL’s board of directors. The bribery scheme was motivated by potential legislation that would...more
Takeaway: Judge’s Broad Interpretation of the FCPA’s Internal Controls Provision and jury conviction make this statute ripe for appellate review....more
In recent years, the US Department of Justice (DOJ) and US Securities & Exchange Commission (SEC) have further defined their anti-corruption due diligence and disclosure expectations of acquiring companies pre- and...more
The SEC announced its first FCPA enforcement action in 2022. South Korean telecommunications company, KT Corporation, agreed to pay $6.3 million to settle FCPA violations. As part of the settlement, KT Corp. agreed to pay...more
A. Basic Overview of Statute - The Foreign Corrupt Practices Act of 1977, as amended, 15 U.S.C. §§ 78dd-1, et seq. (FCPA), makes it unlawful for U.S. persons and entities and others who act within the jurisdiction of the...more
How should you assess your internal controls regime for international operations? It is incumbent that you need to review as much information as you can to understand the financial and operational structure of an entity and...more
What specifically are internal controls in a compliance program? Internal controls are not only the foundation of a company but are also the foundation of any effective anti-corruption compliance program. The starting point...more
The SEC’s FCPA enforcement action against WPP presents a number of important lessons learned, ranging from third-party risk management, properly responding to employee complaints and red flags, and failure to integrate...more
After a long hiatus, the SEC announced a settlement with WPP plc, the world’s largest advertising group, for FCPA violations in India, China, Brazil and Peru for $19.2 million. The SEC’s resolution charges WPP with...more
Companies with business operations in Japan should review due diligence procedures and internal policy regarding small facilitation payments to ensure they are consistent with new guidance from METI. In May 2021, the...more
I conclude my review of the Amec Foster Wheeler (Foster Wheeler) Foreign Corrupt Practices Act (FCPA) enforcement action. Today, I want to close with the result and some key lessons for the 2021 compliance professional. These...more
This week, the Securities and Exchange Commission (SEC) obtained a Final Judgment against Asante Berko, former employee of a Goldman Sachs subsidiary, for, as noted in the SEC Press Release, his role in orchestrating a...more
Deutsche Bank’s ethics and compliance function faces numerous challenges. Deutsche Bank has a storied record of scandals, government enforcement actions and failures to abide by prior deferred prosecution agreements (DPAs)....more
Last week, according to a Department of Justice (DOJ) Press Release, Deutsche Bank Aktiengesellschaft, “agreed to pay more than $130 million to resolve the government’s investigation into violations of the Foreign Corrupt...more