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Corporate Counsel Foreign Corrupt Practices Act (FCPA) Enforcement Actions

A&O Shearman

Looking Back And Moving Forward – 2023 FCPA Enforcement Trends And Patterns

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While 2023 saw a slight increase in the number of FCPA enforcement actions from 2022, there was a marked decline in total penalties from the prior year. Last year, the DOJ and the SEC resolved a total of 14 corporate...more

The Volkov Law Group

John Deere Reaches $9.9 Million Settlement with SEC over FCPA Violations

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The U.S. Securities and Exchange Commission (“SEC”) recently instituted proceedings against Deere & Company (“John Deere”), a leading global manufacturer of agricultural and heavy machinery, for multiple violations of the...more

The Volkov Law Group

Trafigura Joins the FCPA Enforcement Club: Pleads Guilty and Pays Over $126 Million for Bribery Violations in Brazil (Part I of...

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On the heels of the Gunvor FCPA settlement for $661 million, DOJ announced its settlement with Trafigura, the latest commodities trading company to fall under DOJ’s FCPA Sweep against the industry.  Trafigura joined the list...more

Orrick, Herrington & Sutcliffe LLP

The SEC’s New Focus on International Big Tech: What Companies Need to Know

The Securities and Exchange Commission (SEC) Enforcement Division has launched an investigative initiative targeting the use of contractors and distributors by public technology companies operating internationally. The...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for February 2024

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

Morrison & Foerster LLP

Top 5 SEC Enforcement Developments for January 2024

Each month we publish a roundup of the most important SEC enforcement developments for busy in-house lawyers and compliance professionals. This month, we examine: •The SEC’s approval of spot bitcoin ETPs; - •SEC charges...more

Morrison & Foerster LLP

MoFo's 2023 FCPA Year in Review

Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, our Foreign Corrupt Practices Act (FCPA) Year In Review provides quick, visual representations of key trends in FCPA enforcement over...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for November 2023

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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

Clear Channel Settles SEC FCPA Case Against Former Chinese Subsidiary for $26.1 Million

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The Securities and Exchange Commission continues to rack up FCPA enforcement actions.  In its latest settlement, Clear Channel Outdoor Holdings agreed to pay $26.1 million for bribery violations committed by its former...more

Hogan Lovells

The DOJ issues rare Opinion Release on foreign government official travel

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The Department of Justice (DOJ) recently issued a rare FCPA Opinion Procedure Release concerning travel of foreign government officials. Our lawyers analyze the opinion and highlight key considerations for companies engaged...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

Bradley Arant Boult Cummings LLP

Philips Agrees to Pay $62M to Settle FCPA Books-and-Records Violations from Efforts to Win Chinese Contracts

Koninklijke Philips N.V., a global medical technology manufacturer, recently agreed to pay over $62 million to resolve a Foreign Corrupt Practices Act (FCPA) enforcement action with the Securities and Exchange Commission...more

Foley Hoag LLP - White Collar Law &...

Foreign Corrupt Practices Act (FCPA) | 2022 Year in Review and a Look Ahead

U.S. Policy Developments - Since the fall of 2022, DOJ has made several policy pronouncements in connection with its efforts to combat corporate crime. While it remains to be seen how these policies will ultimately affect...more

Jones Day

FCPA 2022 Year in Review

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Foreign Corrupt Practices Act (“FCPA”) enforcement has yet to rebound from the immediate pre-pandemic period. In 2022, DOJ and SEC resolved eight corporate FCPA matters for $878 million, including four resolutions coordinated...more

Vinson & Elkins LLP

Carrots Take Root: DOJ Significantly Revamps Corporate Enforcement Policy to Increase Incentives for Companies to Cooperate

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In an apparent response to a downturn in corporate cases and criticism that its harsh rhetoric was chilling corporate cooperation, the Department of Justice (“DOJ”) recently announced significant changes to its policy on...more

NAVEX

The Justice Department Steps Up Its Compliance Message

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The U.S. Justice Department unveiled new policies about how it will prosecute cases of corporate misconduct, offering new incentives for companies whose misconduct includes “aggravating circumstances” to step forward and...more

The Volkov Law Group

2022: The FCPA Year in Review

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The Justice Department and the Securities and Exchange Commission bounced back in 2022 to restore their records for aggressive FCPA enforcement.  At the same time, DOJ announced significant new compliance program...more

Wiley Rein LLP

SEC Annual Whistleblower and Enforcement Reports Signal Continued Aggressiveness in 2023 and Beyond

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On November 15, 2022 the U.S. Securities and Exchange Commission (SEC) released its Dodd-Frank Whistleblower Program fiscal year (FY) 2022 Annual Report to Congress. The same day, the SEC reported on the Enforcement...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for September 2022

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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 case developments from the past month,...more

The Volkov Law Group

Oracle’s FCPA Violations: A Lesson in Managing Third-Party Distributor Risks (Part II of II)

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Oracle’s SEC settlement for $23 million underscores the power of the FCPA provisions mandating effective internal controls and accurate books and records.  As everyone knows, these provisions can be applied to a wide-range of...more

Butler Snow LLP

Company Cooperation Leads to Criminal Discovery

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When a company discovers that a crime may have been committed by individuals within the company, or is alerted by the government of that possibility, the company will often hire an outside law firm to conduct an internal...more

The Volkov Law Group

DOJ and SEC Secure $41 Million Settlement from Brazilian Airline for FCPA Violations (Part I of II)

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The Department of Justice and the Securities and Exchange Commission reached a $41 million settlement with GOL Linhas Aéreas Inteligentes S.A. (“GOL”) to resolve criminal and civil foreign bribery charges....more

Brownstein Hyatt Farber Schreck

DOJ Introduces a Mix of ‘Carrots and Sticks’ to Combat Corporate Crime

The Department of Justice is sending a clear message to companies when it comes to corporate crime: invest in strong compliance structures and culture and come forward quickly with information about misconduct—or suffer the...more

McDermott Will & Emery

DOJ Revamps Corporate Criminal Enforcement Policies with Continued Emphasis on Compliance

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At a September 15, 2022, speech at New York University School of Law, US Deputy Attorney General (Deputy AG) Lisa Monaco announced several new policies intended to further the aggressive stance the US Department of Justice...more

Perkins Coie

DOJ Announces Sweeping Policy Updates Targeting Corporate Criminal Enforcement and Individual Accountability

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Deputy Attorney General (DAG) Lisa Monaco announced several significant policy updates affecting the U.S. Department of Justice’s (DOJ) enforcement practices for both corporations and individuals on September 15, 2022...more

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