News & Analysis as of

Bribery Securities and Exchange Commission (SEC) Criminal Prosecution

Woodruff Sawyer

Dialing for Dollars: Taking Stock of The DOJ’s New Whistleblower Program

Woodruff Sawyer on

America has always loved stories about people who made it big. Abraham Lincoln grew up in a log cabin; 200 years later, he got his own biopic starring Daniel Day-Lewis. Oprah was born into poverty in rural Mississippi;...more

Thomas Fox - Compliance Evangelist

The SAP FCPA Enforcement Action-Part 2: The Box Score of Corruption

We continue our exploration of the Foreign Corrupt Practices Act (FCPA) enforcement involving the German software company, SAP. The company agreed to pay the Department of Justice (DOJ) and Securities and Exchange Commission...more

Thomas Fox - Compliance Evangelist

The SAP FCPA Enforcement Action-Part 1: Introduction

The year in Foreign Corrupt Practices Act (FCPA) enforcement started off with a bang on January 10 with the announcement of a resolution of the outstanding SAP enforcement action. The bribery schemes used by SAP were massive...more

Hogan Lovells

No monkey business – Recent FCPA probe into wildlife trafficking in Asia

Hogan Lovells on

An Indiana-based contract research organization for pharmaceutical testing is being investigated by the Securities and Exchange Commission (SEC) for potential violations of the Foreign Corrupt Practices Act (FCPA). The...more

Thomas Fox - Compliance Evangelist

Albemarle FCPA Enforcement Action: Part 4 – Internal Control Failures

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

A&O Shearman

Corficolombiana Pays $80M To Resolve Bribery Probes

A&O Shearman on

On August 10, 2023, the U.S. Securities Exchange Commission (“SEC”) and the Department of Justice (“DOJ”), in coordination with Columbian authorities, announced that Colombian conglomerate Grupo Aval Acciones y Valores S.A...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for May 2023

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

The Volkov Law Group

Ericsson Settles Breach of 2019 FCPA Deferred Prosecution Agreement: Agrees to Plead Guilty, Pay $206 Million, and Extend...

The Volkov Law Group on

Ericsson, a multinational telecommunications company, based in Sweden, settled its breach of its 2019 Deferred Prosecution Agreement, agreed to enter a guilty plea and pay a $206 million penalty.  In 2019, Ericsson entered...more

Thomas Fox - Compliance Evangelist

ABB FCPA Resolution: Part 4 – ABB Shines

We continue our exploration of the latest resolution of a Foreign Corruption Practices Act (FCPA) violation involving the Swiss construction giant, ABB Ltd. The most obvious significance is from the fact that ABB is now the...more

The Volkov Law Group

Goldman Sachs Official Indicted Over Ghana Bribery Scheme (Part I of II)

The Volkov Law Group on

Talk about a reminder of the past, Asante Berko, a former Executive Director in Goldman Sachs, recently was arrested in London on criminal FCPA charges arising from his involvement in a bribery scheme in Ghana....more

WilmerHale

Second Circuit Limits Reach of FCPA’s Anti-Bribery Provisions Charged Under Agency Principles

WilmerHale on

On August 12, 2022, the US Court of Appeals for the Second Circuit issued another decision in a long-running criminal action that holds significant implications for the reach of the US Foreign Corrupt Practices Act (FCPA)...more

Bass, Berry & Sims PLC

Update on FCPA Enforcement: First Half of 2022 Sees Major Enforcement Action

Bass, Berry & Sims PLC on

Since late March, the U.S. government has announced several significant enforcement actions under the Foreign Corrupt Practices Act (FCPA), the main U.S. law that prohibits bribery of non-U.S. government officials....more

Goodwin

2021 Year in Review: FCPA

Goodwin on

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

The Volkov Law Group

FCPA Potpourri: Catching Up with FCPA Enforcement

The Volkov Law Group on

While we wait for the coming FCPA enforcement storm, DOJ and the SEC have quietly continued to rack up and resolve several enforcement actions....more

The Volkov Law Group

A Deep Dive into WPP’s Bribery Schemes in India, China, Brazil and Peru (Part II of III)

The Volkov Law Group on

The SEC’s FCPA settlement with WPP for over $19.2 million provides a variety of bribery schemes in several high-risk venues. The schemes are instructive because they remind anti-corruption compliance professionals of the...more

The Volkov Law Group

DOJ and SEC Announce First Corporate FCPA Settlement for 2021: Amec Foster Wheeler, a Wood Group Subsidiary, Agrees to Pay over...

The Volkov Law Group on

The Justice Department and the Securities Exchange Commission are back in business.  The first corporate FCPA enforcement action in 2021 came after a six-month hiatus in 2021.  While many commentators sought to read the...more

Miller Canfield

Record Level of FCPA Enforcement in 2020 Highlights Key Risk Areas

Miller Canfield on

The year 2020 witnessed a record level of $2.78 billion in corporate fines and penalties from enforcement of the Foreign Corrupt Practices Act (FCPA) by the U.S. Department of Justice (DOJ) and the U.S. Securities and...more

WilmerHale

Global Anti-Bribery Year-in-Review: 2020 Developments and Predictions for 2021

WilmerHale on

As was true in many areas of the law, Foreign Corrupt Practices Act (FCPA) enforcement in 2020 - and anti-corruption enforcement more generally - was affected by the COVID-19 pandemic, but perhaps not as much as was initially...more

Bass, Berry & Sims PLC

FCPA Update: Enforcement Continues

Bass, Berry & Sims PLC on

In recent months, the U.S. Department of Justice (DOJ) and Securities & Exchange Commission (SEC) have announced several notable penalties for violations of the U.S. Foreign Corrupt Practices Act (FCPA). The FCPA prohibits...more

Jones Day

FCPA 2020 Year in Review

Jones Day on

In 2020, the biggest Foreign Corrupt Practices Act (“FCPA”) headline was the record-shattering global anticorruption enforcement fines and penalties collected by foreign regulators in actions involving a coordinated FCPA...more

Thomas Fox - Compliance Evangelist

Top 5 Blog Posts in 2020

As we move towards one year that most everyone is ready to exit, I wanted to consider some of the key enforcement actions from both the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) in 2020. You...more

The Volkov Law Group

Goldman Sachs and the Economic Impact of Corruption

The Volkov Law Group on

The breadth of Goldman Sachs’ corruption in the recent DOJ and SEC FCPA enforcement action underscored the important global goal of reducing corruption.  It goes without saying – corruption has a pernicious impact on economic...more

The Volkov Law Group

Goldman Sachs Settles Massive 1MDB Bribery Case and Agrees to Pay Nearly $3 Billion (Part I of III)

The Volkov Law Group on

The Justice Department finally closed out its investigation of Goldman Sachs’ massive bribery scheme involving Malaysia’s 1MDB fund.  The case is now the largest in US FCPA history (based on its payment to DOJ and related US...more

The Volkov Law Group

J&F Investmentos Pleads Guilty to FCPA Bribery Conspiracy and Settles SEC Case for Total of $283 Million (Part I of V)

The Volkov Law Group on

J&F Investmentos SA (“J&F), a Brazilian private investment company, plead guilty to FCPA bribery violations in federal court in Brooklyn, New York.  As part of the plea agreement, J&F agreed to pay a fine of $256 million and...more

K&L Gates LLP

Voluntary Disclosure: Newsflash – October 2020

K&L Gates LLP on

In this episode, we examine how two criminal defendants are aiming to leverage parallel FCPA investigations by the SEC and the DOJ to build their defense. We’ll also offer our thoughts on the SEC’s new (and improved?)...more

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