10 For 10: Top Compliance Stories For the Week Ending May 10, 2025
Compliance into the Weeds: USRA Declination Case Study - Self-Disclosure Best Practices
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
On March 4, 2025, one day before a trial against former tech executives for alleged foreign bribery charges was set to commence, the United States Attorney for the District of New Jersey requested 180-day adjournment. The...more
Commercial bribery enforcement also became more active, as the authorities marked the 30th anniversary of the PRC Anti-Unfair Competition Law. The revision of the PRC Anti-Espionage Law raised some concerns about national...more
Last week, Airbus SE (Airbus) settled a long-standing corruption scandal by agreeing to enforcement actions in three countries; France, the United Kingdom and the US. The matter involved a massive, worldwide, long running...more
In a blockbuster case, the Justice Department announced a global settlement with Airbus SE, a manufacturer of civilian and military aircraft, under which Airbus agreed to pay over $4 billion (yes, with a “B”) to resolve...more
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
ANTICORRUPTION DEVELOPMENTS - Telecommunications Company Fined $12 Million for FCPA Violations - On August 29, 2019, The Securities and Exchange Commission (SEC) instituted ceaseand-desist proceedings against...more
Initially, it would not seem that much was new or different about the Microsoft FCPA enforcement action but through this exploration, I think some clear lessons have emerge. The first is around internal controls. Here there...more
Microsoft’s bribery and controls violations reflect significant risks facing companies that rely on distributor and reseller networks to sell their products. Companies often enter and operate in emerging markets through...more
Continuing our use of great drum solos to consider the Microsoft Foreign Corrupt Practices Act (FCPA) enforcement action, today we consider what Microsoft did to obtain their result. We have previously considered the...more
Microsoft finally resolved its FCPA enforcement action with a whimper. Notwithstanding prior suggestions that Microsoft’s investigation uncovered global conduct, Microsoft’s liability focused primarily on Microsoft’s conduct...more
Microsoft Hungary agreed to pay approximately $8.5 million to the DOJ. Together with the amounts paid to the SEC in profit disgorgement, the total is just over $25 million. Microsoft Hungary received a 25% discount off the...more
Tech companies of U.S. origin tend to have compliance programs focused on U.S. laws, including the Foreign Corrupt Practices Act (the "FCPA") and relevant tax and labor laws. The UK has enacted laws covering bribery and...more
ANTICORRUPTION DEVELOPMENTS - DOJ Files Superseding Indictment in Haitian Port Corruption Plot - On October 30, 2018, the U.S. Department of Justice (DOJ) filed a superseding indictment in the District of Massachusetts...more
Those bemoaning the lack of Foreign Corrupt Practices Act (FCPA) enforcement activity can cease. With the Dun & Bradstreet Inc. (D&B) declination last week and this week’s enforcement action involving Panasonic Avionics...more
In October 2017 at the Chinese Communist Party National Congress, President Xi Jinping consolidated his hold on power and cemented himself as what many commentators are calling the most powerful Chinese leader since Mao...more
A collection of corporate heavy hitters are betting big on the blockchain technology behind bitcoin rival Ethereum to build a computing system to track data and financial contracts. The project is seen by some as a way to...more
Acting SEC Chair Michael Piwowar has reportedly scaled back some of the agency’s enforcement staff’s use of delegated authority by funneling all subpoena issuance and probe initiation through the SEC’s director of...more
On the Hill yesterday, Fed Chair Yellen acknowledged that the recent election would likely mean changes for the economy, but she said it was “too soon” to predict the nature of that economic impact at this time (though that...more
Just to add my voice to the cottage industry surrounding FCPA enforcement and compliance, I wanted to take a deep breath and offer some observations on FCPA enforcement in 2016. There are a few significant headlines...more
DOJ’s FCPA Unit knows what they are doing. In the immediate weeks after the release of the FCPA Pilot Program, DOJ publicly released two declination letters for Akamai Technologies and Nortek, Inc. and the SEC announced...more
On Aug. 12, 2015, Vincente Garcia (former head of Latin American sales for SAP International Inc.) pled guilty in federal court in San Francisco to violations of the Foreign Corrupt Practices Act. In addition to pleading...more