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Compliance Dept. of Justice The Foreign Corrupt Practices Act

Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory... more +
Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory violations.  In response to many corporate scandals evidencing rampant unethical business practices, many nations, including the United States, began passing strict regulatory frameworks aimed at curbing these abuses. Notable pieces of legislation in this area include the U.S. Foreign Corrupt Practices Act (FCPA), Sarbanes-Oxley (SOX), and the U.K. Bribery Act, to name a few. The foregoing statutes and the severe penalties often associated with them form the basis of many modern institutional compliance programs. less -

This Week in FCPA-Episode 77, the Home for the Holidays Edition

by Thomas Fox on

Jay and I return for a wide-ranging discussion on some of the top compliance and ethics related stories of the week, including: 1. The DOJ/SEC FCPA Guidance turned 5 years old this week. For the compliance practitioner,...more

Everything Compliance Reports from the SCCE 2017 Compliance & Ethics Institute [eBook]

by Thomas Fox on

In October 2017, nearly 2000 compliance professionals gathered in Las Vegas for the annual Society of Corporate Compliance and Ethics (SCCE) Compliance and Ethics Institute. The event was a great success for all involved, it...more

DOJ – Aggressive International Anti-Corruption Enforcement to Continue

by Thomas Fox on

Acting Assistant Attorney General Ken Blanco spoke yesterday at FCPA/OECD Anniversary Conference at the NYU School of Law. His remarks made clear not only the importance of enforcement of laws against bribery and corruption...more

Rolls Royce in America – Four Guilty Pleas and an Indictment

by Thomas Fox on

For those who might have wondered if the Sessions Justice Department (DOJ) was going to enforce the Foreign Corrupt Practices Act (FCPA), that question seems to have been answered in the affirmative. In September, the DOJ and...more

Anti-Corruption Risks: Global Enforcement Means Global Detection

by Michael Volkov on

Over the last year, we have seen the Justice Department and SEC’s international coordination efforts bear fruit. DOJ has expended time and efforts to train prosecutors and law enforcement on anti-corruption investigations and...more

Astros Garner First World Series Win – Execution of Compliance in the Middle

by Thomas Fox on

In compliance you often times need to be a superior utility player who is good at every job. There are multiple lessons. First and foremost is the problem of siloing in corporate America. This concern of siloing even...more

FCPA Enforcement and Credit for an Effective Compliance Program

by Michael Volkov on

The Justice Department has touted its efforts to bring greater transparency to FCPA enforcement. There is no question that in the last five years the Justice Department has moved the needle – the FCPA Guidance issued in 2012;...more

Who Knows What Corrupt Lives in the Hearts of Men: the Telia FCPA Resolution

by Thomas Fox on

While the resolution of the Telia FCPA matter has long been awaited, the results announced in September by the Department of Justice and Securities and Exchange Commission were stunning nonetheless....more

Compliance Man Goes Global-Episode 4-Training

by Thomas Fox on

Welcome to Episode 4 of Compliance Man Goes Global podcast of FCPA Compliance Report International Edition. In this episode, we will focus on typical myths and mistakes regarding compliance trainings. In each podcast, we take...more

Using Strategic Risk to Your Advantage

by Thomas Fox on

I am beginning to feel this week’s theme becoming all-encompassing. As hard as I might try, it looks like it will be the Houston Astros second World Series appearance. During the first one back in 2005, I was in the corporate...more

Deputy Attorney General Announces Comprehensive Review of DOJ Corporate Enforcement Policies

by Latham & Watkins LLP on

Key Points: - DOJ is reviewing and reevaluating numerous corporate enforcement policies, including the “Yates Memo,” the FCPA Pilot Program, and policies on corporate monitors. - Policies will be codified in official...more

The Halliburton FCPA Enforcement Action - Lessons for Chief Compliance Officers on Internal Controls Failures

by Thomas Fox on

One takeaway of the Halliburton-Sonangol FCPA enforcement action? Trust but verify....more

An Exploration of Soft Skills in Remediation for the Chief Compliance Officer

by Thomas Fox on

Many have focused on the more technical aspects of the remediation component of a potential Foreign Corrupt Practices Act compliance violation. I wanted to explore the soft skills that a CCO must use, both internally and...more

Farewell to The Hawk – Fair and Consistent Application of Discipline

by Thomas Fox on

In the Department of Justice’s (DOJ’s) Evaluation of Corporate Compliance Programs (Evaluation), Prong 8 Incentive and Disciplinary Measures it states: Incentive System – Consistent Application – Have the disciplinary actions...more

Where O’ Where Did Our Monitors Go? — The Telia Bribery Case

by Michael Volkov on

Just when everyone was anticipating the beginning of an uptick in FCPA enforcement in 2017, the Justice Department and the SEC delivered a resounding message to remind everyone that FCPA enforcement is here to stay. However,...more

Lessons for Compliance Officers from Hurricane Harvey and Other Historic Weather-Related Events

by Thomas Fox on

Lessons for the corporate compliance professional from Hurricane Harvey and other weather-related disasters....more

The Fraud Triangle, Rationalizations and Compliance Programs

by Thomas Fox on

The fraud triangle is well-known to most compliance practitioners. Its third sides are pressure, opportunity and rationalization. When these three factors converge, there is danger of an ethical lapse which could lead to...more

Tribute To Gogos – New Corruption Scandal In College Sports

by Thomas Fox on

October is my annual Classic Monster Movie month tribute. I recognize it is not yet October but I wanted to begin a bit early this year as September saw the passing of Basil Gogos. He was the prime illustrator for the...more

Telia FCPA Enforcement Action: Part IV – Getting Some Monies Back

by Thomas Fox on

I have spent the past few blog posts reviewing the many lessons that can be garnered by the compliance practitioner from the Telia Company AB (Telia) Foreign Corrupt Practices Act (FCPA) resolution. However, there is one...more

The Telia FCPA Resolution: Part III – The Individuals

by Thomas Fox on

I continue my exploration of the Telia Company AB (Telia) Foreign Corrupt Practices Act (FCPA) enforcement action and the parallel actions. Today I will consider the individuals who have been criminally indicted in Sweden and...more

DOJ And SEC Bring Major FCPA Enforcement Actions Against Swedish Telecom Firm, Imposing One Of Largest FCPA Penalties In History

by Shearman & Sterling LLP on

On September 21, 2017, the Department of Justice (“DOJ”) and Securities and Exchange Commission (“SEC”) announced significant enforcement actions against Telia Company AB, a Swedish telecommunications firm, for alleged...more

In the Third-Largest FCPA Enforcement Action Ever, Telia Agrees to Pay Almost $1 Billion to Resolve Bribery Inquiry in Uzbekistan;...

by Ropes & Gray LLP on

In the first blockbuster FCPA action of the Trump administration, on September 21, 2017, Swedish telecommunications company Telia agreed to pay $965 million in total penalties to the U.S. Department of Justice (“DOJ”) and...more

The Telia FCPA Resolution: Part II – The Bribery Schemes

by Thomas Fox on

Over the next few blog posts, I will be exploring the resolution and what lessons the compliance practitioner can draw from the Telia Company Foreign Corrupt Practices Act, (FCPA) enforcement action, the parallel actions and...more

The Telia FCPA Resolution, Part I

by Thomas Fox on

While the resolution of the Telia Company (Telia) Foreign Corrupt Practices Act (FCPA) matter has long been awaited, the results announced yesterday by the Department of Justice (DOJ) and Securities and Exchange Commission...more

Diwali: An Opportune Time for an Anti-Corruption Compliance Reminder

by Foley & Lardner LLP on

This year, India celebrates Diwali on October 19, 2017. “The Festival of Lights,” as Diwali (or Deepavli) is commonly called, is celebrated across India with great aplomb, joy and, of course, delicious sweets. Diwali...more

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