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
Episode 296 -- Deep Dive into Clear Channels SEC Settlement of FCPA Violations
Episode 294 -- Catch Up on OFAC Enforcement: 3M and Emigrant Bank
The Maritime Anti-Corruption Network: An In-Depth Conversation
Season 2 - Episode 2 - A Whistleblowers Nightmare: The Uncovering of the 1Malaysia Development Berhad Scandal
The Justice Insiders Podcast: Varsity Blues Reversals Turn DOJ Red
Corruption, Crime, and Compliance - The Ericsson FCPA DPA Breach Settlement
Episode 258 -- Deep Dive into ABB FCPA Settlement
Corruption Crime & Compliance - Deep Dive into the ABB FCPA Case
Life with GDPR - The ABB Enforcement Action from a UK Perspective
The Corruption Files - Episode 15 - The ABB Settlement
The Line Between Gift Giving and Bribery
The Corruption Files - Episode 14 - Walmart with Tom Fox and Michael DeBernardis
Compliance Into The Weeds - Lafarge and the Cost of Moral Bankruptcy
The New Cold War: Risk, Sanctions, Compliance Episode 21: "Interview with Drago Kos of the OECD Working Group on Bribery"
The Justice Insiders: FIFA Corruption Trial – Will the Feds Score Another Goal?
The Presumption of Innocence Podcast: Episode 5 - Doing Business Overseas: The Foreign Corrupt Practices Act
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
Motivated by a “visceral reaction” to large-scale economic crime, Nick Ephgrave lays out vision for a bolder, more pragmatic, and more proactive agency. Whistleblowers, dawn raids, and cross-agency collaboration are all...more
In yet another indication that the Biden administration is continuing to ramp up white collar enforcement, the U.S. Department of Justice (“DOJ”) and Securities and Exchange Commission (“SEC”) announced on April 20, 2022 that...more
The Serious Fraud Office (“SFO”) has recently updated its Operational Handbook to include a chapter on DPAs (the "Updated Handbook"). For companies under investigation, the question of whether or not to cooperate with the...more
A recurring question of general counsel and chief compliance officers is whether their proactive investments in compliance programs, voluntary self-disclosure of issues, and cooperation will be meaningfully rewarded. For too...more
Previously, we introduced you to this topic and provided updates about the positive international trends in anti-corruption efforts, bribery, and the Organization for Economic Cooperation and Development (OECD). Today, we...more
On 16 July 2019, three individuals were acquitted of conspiracy to corrupt and conspiracy to bribe. On the basis of the same evidence, their employer, Sarclad Limited, had previously admitted corporate criminal liability and...more
We continue our exploration of the TechnipFMC Foreign Corrupt Practices Act (FCPA) enforcement action by considering the actions taken by the company (or both separately before their merger) in response to their FCPA...more
The CFTC announced an Enforcement Advisory on self-reporting and cooperation for violations of the Commodity Exchange Act, or CEA, involving foreign corrupt practices. ...more
Brief Comments on The Director of the Serious Fraud Office v. Eurasian Natural Resources Corporation Limited [2018] EWCA Civ 2006 - On Sept. 5, 2018, the Court of Appeal of England and Wales handed down a unanimous...more
The recent conviction of UK company Skansen Interiors Limited (SIL), for the corporate offence of failure to prevent bribery has caused controversy. This is the first conviction under S7 of the Bribery Act after a contested...more
In an important decision given on February 21, 2018, a jury in English court proceedings has considered for the first time what “adequate procedures” should be for the purpose of a defense to the corporate offense of failing...more
The Australian government agencies responsible for investigating and prosecuting foreign bribery have released joint best practice guidelines that indicate how they will approach self-reporting by companies voluntarily...more
On 6 December 2017, Australia's Federal Government tabled the Crimes Legislation Amendment (Combatting Corporate Crime) Bill 2017 ("Bill"), which contains various amendments to Australia's foreign bribery regime, including...more
The world of science fiction can be exhilarating. If you ever read The Foundation Trilogy or Martian Chronicles, you know what I mean. The concept of parallel universes has always been an intriguing idea where believers can...more
On September 20, 2016, Skadden presented a seminar titled “Government Enforcement Investigations – Trends and Perspectives from the UK, US and China” in London. The UK Financial Conduct Authority (FCA) Director of Enforcement...more
The Foreign Corrupt Practices Act (“FCPA”) prohibits both United States and foreign corporations and nationals from offering or paying, or authorizing the offer or payment, of anything of value to a foreign government...more
A couple of recent articles about the UK Serious Fraud Office (SFO) caught my attention. One was on thebriberyact.com, entitled “Opinion: DPA’s must show greater benefits. We discuss the Criteria & Process for a DPA set out...more
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
Let’s start with a big “If.” I know that sounds like a real turn off but bear with me. Assuming that the Justice Department is ready to turn over a new approach to criminal enforcement and aggressively prosecute culpable...more
Just to add to the cacophony of voices campaigning during this primary season, DOJ, SEC, FINRA, and CFTC officials launched their own campaign promoting recent initiatives to increase corporate self-reporting of potential...more
Welcome to Dorsey & Whitney’s monthly Anti-Corruption Digest. In this digest, we draw together news of enforcement activity throughout the world and aim to reduce your information overload. Our London, Minneapolis, New York...more
Earlier this month, Assistant US Attorney Leslie Caldwell announced that the US Department of Justice’s Criminal Division Fraud Section will try to entice companies to self-report potential FCPA issues. The DOJ included...more
On April 5, 2016, the Department of Justice’s Fraud Section (“DOJ”) issued its Foreign Corrupt Practices Act (“FCPA”) Enforcement Plan and Guidance (“Guidance”), which announced (1) a more than doubling of DOJ resources...more
The Fraud Section of the U.S. Department of Justice’s (DOJ) Criminal Division has announced a new initiative to motivate companies to self-report violations of the Foreign Corrupt Practices Act (FCPA), cooperate with the...more