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CEOs Foreign Corrupt Practices Act (FCPA)

Thomas Fox - Compliance Evangelist

Tone at The Top Week: Part 2 – Ten Things A CEO Can Do

In corporate compliance, a guiding principle is the foundation for success or failure: Tone at the Top. This phrase encapsulates the role of senior executives—particularly the CEO—in setting the ethical standards, cultural...more

McCarter & English, LLP

DOJ Launches Pilot Program to Encourage Reporting of Criminal Activity

The Department of Justice (DOJ) has announced a pilot program to encourage potential whistleblowers to report criminal activity and cooperate with government investigations in exchange for substantial monetary payouts in the...more

Health Care Compliance Association (HCCA)

[Event] 2023 Board & Audit Committee Compliance Conference - October 23rd - 24th, Fort Lauderdale, FL

Discover today's best practices for your role in healthcare compliance oversight - The Office of Inspector General of Health and Human Services expects healthcare board members, board audit/compliance committee members,...more

StoneTurn

5 Tips For Meeting DOJ’s New CCO Certification Requirements

StoneTurn on

The DOJ has signaled that CEO and CCO certifications will become a staple of all corporate settlement agreements. Critics worry CEOs and CCOs face undue personal liability and argue it will dissuade CCOs from accepting the...more

Thomas Fox - Compliance Evangelist

Death of dos Santos and Leadership at the Top

José Eduardo dos Santos, who served nearly four decades as Angola’s president, died on Friday in Spain where he had been living in self-imposed exile. According to his New York Times (NYT) obituary, “he was widely accused of...more

Guidepost Solutions LLC

The Sky Will Not Fall with New Justice Department CEO / CCO Certifications; Instead, the Sun Will Shine

Despite an industry uproar, the sky is NOT falling with the U.S. Department of Justice (“DoJ”) requirement that chief executive officers (“CEOs”) and chief compliance officers (“CCOs”) certify that their compliance programs...more

McGuireWoods LLP

The Perils of Global Expansion: World’s Largest Ad Agency Sanctioned $19 Million for FCPA Violations, Insufficient Controls

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Global expansion without adequate controls is asking for trouble. That’s the lesson of a $19 million settlement between WPP, the world’s largest advertising agency, and the U.S. Securities and Exchange Commission (SEC) to...more

Porter Hedges LLP

World’s Largest Advertising Group Settles with SEC for $19.2 Million After Ignoring Red Flags

Porter Hedges LLP on

On September 24, 2021, the Securities and Exchange Commission (“SEC”) announced a settlement with WPP plc, the world’s largest advertising group with dual headquarters in New York City and London. According to the SEC’s...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments For April 2021

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

Thomas Fox - Compliance Evangelist

Communication through persuasion

Even with this most turbulent year nearly at an end, we continue to lose many true greats. One of the greatest in baseball in the ‘60s and ‘70s was Richie (Dick) Allen. According to Tyler Kepner, writing in his On Baseball...more

Thomas Fox - Compliance Evangelist

Why the Board of Directors Need an Investigation Protocol

Many companies have an investigation protocol in place when a potential compliance or other legal issue arises. However, many Boards of Directors do not have the same rigor when it comes to an investigation, which should be...more

Oberheiden P.C.

A CEO's Guide to FCPA Compliance

Oberheiden P.C. on

- A tone-at-the-top business culture with CEO leadership is a critical component of effective anti-corruption and anti-bribery policy implementation. - CEO leadership helps set an example for lower management and company...more

Thomas Fox - Compliance Evangelist

Executives Acting in Bad Faith and the Role of the Board

A piece by Dick Cassin in the FCPA Blog had some very stark language. He quoted from the Telefonaktiebolaget LM Ericsson (Ericsson) 6-K filing for the following, “While the Company had a compliance program and a supporting...more

The Volkov Law Group

Ericsson’s Pervasive Bribery Conduct: The Toxic Mix of Senior Executive Involvement and Third Party Corruption (Part II of II)

The Volkov Law Group on

Ericsson’s FCPA settlement is in the books (not the books and records).  But it casts a significant shadow across the FCPA landscape.  A pervasive and systemic culture of bribery is defined to reflect senior executive...more

The Volkov Law Group

Episode 117 -- FCPA Update: Samsung FCPA Settlement; Braskem Former CEO Indicted; Transport CEO Convicted after Trial

The Volkov Law Group on

The Justice Department has been very busy in FCPA enforcement matters -- (1) Samsung Heavy Industries paid $75 million to settle FCPA violations; (2) Braskem's former CEO was indicted on FCPA charges; and (3) after a...more

Thomas Fox - Compliance Evangelist

Westport Fuel Systems – Control Fraud at Its Finest

Today, I conclude my short exploration of the recent spate of Foreign Corrupt Practices Act (FCPA) enforcement actions brought by the Securities and Exchange Commission (SEC) at the close of its fiscal year. Each FCPA...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - February 2019

ANTICORRUPTION DEVELOPMENTS - DOJ Unseals Indictment of Two More Individuals Connected With PDVSA Corruption Scheme - On February 26, 2019, the U.S. Department of Justice (DOJ) announced the unsealing of an indictment...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - September 2018

ANTICORRUPTION DEVELOPMENTS - Petrobras Settles with U.S. Authorities Over Alleged FCPA Violations - On September 27, 2018, the U.S. Department of Justice (DOJ) and the Securities and Exchange Commission (SEC)...more

Foley & Lardner LLP

The Twelve Compliance Steps Every Multinational Corporation Should Undertake in Light of Recent Trump Administration Enforcement...

Foley & Lardner LLP on

Over the last month, regulators with the Trump administration sent a loud message to companies subject to U.S. jurisdiction: Enforcement of laws governing international activities is alive and well and the laws will continue...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - Russian

ANTICORRUPTION DEVELOPMENTS – U.S. Agencies Decline to Prosecute Teradata for Alleged FCPA Violations – On February 26, 2018, Teradata Corporation, an Ohio-based enterprise software database management company,...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - Chinese

ANTICORRUPTION DEVELOPMENTS – U.S. Agencies Decline to Prosecute Teradata for Alleged FCPA Violations – On February 26, 2018, Teradata Corporation, an Ohio-based enterprise software database management company,...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - February 2018

ANTICORRUPTION DEVELOPMENTS – U.S. Agencies Decline to Prosecute Teradata for Alleged FCPA Violations – On February 26, 2018, Teradata Corporation, an Ohio-based enterprise software database management company,...more

Thomas Fox - Compliance Evangelist

This Week in FCPA- Episode 52, for the week ending May 12, the Firing the Investigators Edition

1. What is the real risk in a FCPA enforcement action? See Mike Volkov’s post in Corruption, Crime and Compliance. 2. FIFA fires its lead internal investigators for doing their job investigating. See Tom’s article in...more

Thomas Fox - Compliance Evangelist

Four Essential Leadership Behaviors

The role of any leader should be engagement, engagement and then more engagement. By understanding the needs of your key stakeholders and incorporating that into your solution or initiative you will have your team on board...more

Thomas Fox - Compliance Evangelist

Will Culture Change at Uber Before It’s Too Late?

What happens when a company delivers a superior product or service which is enthusiastically embraced by the consuming public, has a contented, if not equally enthusiastic, public facing work force and the business itself...more

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