FCPA Compliance Report - James Koukios on the Monaco Speech
Guidepost in Motion - Evolution of the Monitor’s Role in Identifying Problems + Implementing Change
Compliance Perspectives: Volkswagen's Transformation
FCPA Compliance Report-Episode 511 – Jay Rosen on the Lack of Monitorship
Compliance Perspectives: Monitorships During the Pandemic
Compliance Perspectives: Delaware Supreme Court’s Marchand v. Barnhill Decision
Compliance Perspectives: Auditing and Monitoring Third Parties
Episode 119 -- The Ericsson FCPA Settlement
Compliance Perspectives: Current Trends in Third Party Risk Management
Independent Monitoring and Proactive Assessments for Defense Attorneys-Part 1, Introduction
Working with Monitors-Episode V: Lawyers Using Monitors
Working with Monitors-Episode III: How Do Monitors Work
Working with Monitors-Episode II: Impacts of Monitors
Day 18 of One Month to More Effective Continuous Improvement-Email Sweeps for Continuous Improvement
Day 16 of One Month to More Effective Continuous Improvement-Voluntary Monitoring
No Longer Just a Matter of Paying the Fine and Moving On. Corporate settlement agreements used to be straightforward—pay the penalty and move on. Now, these resolutions rival complex business transactions, including...more
Preventing Organizational Conflict of Interest Federal Acquisition Act, P.L. No 117-324 (January 3, 2023) The FAR 9.5 OCI provisions have been out-of-step with practice for well over a decade. Government and private...more
ELON’S MUSK TUMULTUOUS HISTORY WITH THE SEC - Tesla’s colorful CEO, Elon Musk, has a history of feuding with the Securities and Exchange Commission (SEC), and it looks like the fight isn’t over. In 2018, the SEC...more
This LawFlash summarizes key takeaways from the American Conference Institute’s (ACI’s) 38th International Conference on the Foreign Corrupt Practices Act (FCPA), where top government officials offered insight and...more
In this third edition of October HorrorFest 2020 celebration we consider the first Hammer film sequel (and second in the series) – The Revenge of Frankenstein which was released in 1958. It begins as the Curse of Frankenstein...more
The U.S. Government’s 2019 FCPA enforcement efforts led to new milestones; further cooperation with international authorities; and continued use of independent corporate monitors. The following are key takeaways of these...more
On December 6, 2019, Telefonaktiebolaget LM Ericsson (Ericsson or the Company), resolved long-running investigations by the U.S. Department of Justice (DOJ) and the U.S. Securities and Exchange Commission (SEC) into the...more
Last week the Justice Department (DOJ) announced a resolution of the long stand Foreign Corrupt Practices Act (FCPA) enforcement action involving Telefonaktiebolaget LM Ericsson (Ericsson), a multinational networking and...more
The Sweden-based telecommunications company, Ericsson, agreed to a pay a total of $1 billion (yes, billion with a “B”) for FCPA violations. Ericsson entered into settlement agreements with DOJ and the SEC. Ericsson agreed to...more
The big one finally is resolved. The long-awaited Walmart Inc. (Walmart) Foreign Corrupt Practices Act (FCPA) enforcement action was announced yesterday. This massive case came in with multiple documents, a long list of...more
On March 6, 2019, Mobile TeleSystems PJSC (MTS) consented to pay an $850 million sanction—the largest Foreign Corrupt Practices Act (FCPA) criminal penalty ever paid to the United States—and to a three-year monitorship to...more
In a stunning resolution to one of the longest running bribery, corruption and money-laundering sagas on the international stage, the Department of Justice (DOJ) and Securities Exchange Commission (SEC) both announced...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
• Four years ago, Brazilian authorities began Operation Car Wash, a wide-ranging and still ongoing corruption and money laundering investigation that has spanned 11 countries. • The fallout continues with a recent U.S....more
There are two distinct themes in FCPA enforcement – the first is consistency, i.e., that some enforcement actions are relatively consistent across the board and, in the last five to ten years, the FCPA caseload has been...more
Cybersecurity is “hot” and will stay “hot” for corporations, executives, regulators, law enforcement and legislators. Rarely is there a corporate compliance discussion in 2017 where cyber isn’t “the” topic or a material part...more
There are multiple areas in the Department of Justice’s Evaluation of Corporate Compliance Programs which intersect with the area of continuous improvement. In addition to Prong 9. Continuous Improvement, Periodic Testing and...more