News & Analysis as of

Corruption

This Week In Securities Litigation

by Dorsey & Whitney LLP on

The Commission proposed a package of rules and interpretations focused on retail investors. At the center of the package is proposed Regulation Best Choice focused on the relation between brokers and their clients....more

Farewell to Sammartino: The Continued Unraveling of PDVSA Corruption

by Thomas Fox on

Yesterday Cesar David Rincon Godoy (Rincon) pled guilty to a massive money laundering scheme which took the proceeds of his corruption while he was employed at PDVSA. According to the DOJ Press Release, Rincon, a citizen of...more

Anti-Corruption Enforcement: Analyzing the Enforcement Approaches of the US, the UK and France

by Bryan Cave on

Anti-Corruption enforcement is a top priority in France, the UK, and the US. Each of these countries has armed its enforcers with the enforcement tools necessary to investigate and prosecute corporations and individuals. Join...more

Introduction of Corporate Liability for Corruption Offenses in Malaysia

by Reed Smith on

Amendments to Malaysia’s anti-corruption law were recently passed by the lower house of the Malaysian parliament. The main thrust of these amendments, which are set out in the Malaysian Anti-Corruption Commission (Amendment)...more

Anti-Corruption Regulation Survey of 41 Countries 2017–2018

by Jones Day on

Welcome to the 2017-2018 edition of the Jones Day Anti-Corruption Regulation Survey. In 2017 and 2018 to date, there has continued to be an increasing awareness among multinational companies of the significance of...more

CCOs and Compromising Positions

by Michael Volkov on

The chief compliances officer is the guardian of a company’s most important intangible asset – its culture. Everyone at a company is responsible for a company’s culture; the board of directors, CEO, senior executives play an...more

Japan's plea bargaining system

by Hogan Lovells on

A new plea bargaining system – offering reduced penalties to companies that report certain violations and cooperate with government investigations – will come into effect in Japan this June, reflecting an amendment to the...more

Leadership Lessons from James Polk – Mind the Details but Don’t Take Your Eyes off the Goal

by Thomas Fox on

There were two economic issues that Polk accomplished which greatly furthered US economic interests. The first was the reduction of the Tariff of 1842. Polk directed Secretary of the Treasury Robert Walker to draft a lower...more

Nights in White Satin – The Continued Pain at Wells Fargo

by Thomas Fox on

The Wells Fargo scandals continue to be one of the starkest lessons about the cost of a corrupt culture and the catastrophic effect it can have on an organization. The former Chief Executive Officer (CEO) and head of the...more

The Cohen Search Warrants – DOJ Procedures for Approval

by Michael Volkov on

With all the recent hoopla and commentary on the Michael Cohen criminal investigation and the execution of search warrants against Cohen, it is important to focus on what is true, what is exaggerated and what is outright...more

Episode 34 -- The Cohen Criminal Investigation and the Search Warrants

by Michael Volkov on

On April 9, 2018, FBI agents executed search warrants at Michael Cohen's office, hotel, residence, safety deposit box and electronic devices. Since then, we learned that the US Attorney's Office in New York City have an...more

Operationalizing compliance through tailored compliance training

by Thomas Fox on

I have considered this in the context of third-parties, forecasting and the risk management process and through the use of a root cause analysis. Today, I want to conclude this week’s blog posts with a post on...more

OFAC Hits Russia with New Sanctions

by Michael Volkov on

On April 6, 2018, OFAC announced a new round of sanctions against Russian individuals and companies. Relying on its authority under existing executive orders, OFAC designated seven Russian oligarchs and 12 companies they own...more

Red Notice Newsletter - Russian

ANTICORRUPTION DEVELOPMENTS – Canadian Mining Company Settles with SEC over FCPA Charges – On March 26, Kinross Gold Corporation settled with the Securities and Exchange Commission (SEC) over its alleged failure to...more

Red Notice Newsletter - Chinese

ANTICORRUPTION DEVELOPMENTS – Canadian Mining Company Settles with SEC over FCPA Charges – On March 26, Kinross Gold Corporation settled with the Securities and Exchange Commission (SEC) over its alleged failure to...more

A Rift in the Space Time Continuum in a FCPA-Related Shareholder Lawsuit

by Thomas Fox on

A rift in the space time continuum is similar to a tear in fabric, thereby creating a disconnect in this timeline. This is certainly what we saw in the district court’s opinion in EMPLOYEES RETIREMENT SYSTEM OF THE CITY OF...more

Polish anti-bribery laws - revolutionary changes

by Hogan Lovells on

The function of this client alert is to inform you that the Polish anti-bribery law is shortly expected to be thoroughly amended. The changes will, not only concern public entities, but will also have a fundamental impact on...more

The lesser spotted, greatly discussed DPA

by Hogan Lovells on

On 19 March 2018, Singapore's Parliament ushered in a raft of criminal justice reforms, including the significant introduction of a deferred prosecution agreement ("DPA") regime. ...more

Red Notice Newsletter - March 2018

ANTICORRUPTION DEVELOPMENTS – Canadian Mining Company Settles with SEC over FCPA Charges – On March 26, Kinross Gold Corporation settled with the Securities and Exchange Commission (SEC) over its alleged failure to...more

World Series Banners and Red Flags

by Thomas Fox on

The first lesson for the compliance practitioner is that you should actually test your compliance program in high-risk/high-profile situations. The unfurling team likely did practice their unfurling regime but apparently...more

Considerations When Hiring a Monitor

by Thomas Fox on

What are the considerations a company should employ when retaining a corporate monitor? I recently put that question to Vincent L. DiCianni, founder and President of Affiliated Monitors, Inc. (AMI), and Eric R. Feldman,...more

Kinross Gold Mining FCPA Settlement: SEC Continues Internal Controls Focus

by Michael Volkov on

The SEC continues to exercise its powerful enforcement tool – internal controls violations – in FCPA enforcement actions against public companies. Kinross Gold Corporation is the latest company to enter into an FCPA...more

ECI’s New Business Ethics Survey Confirms Misconduct Rates Declining — But Retaliation Rates Increasing

by Michael Volkov on

The Ethics and Compliance Institute recently released the results of its global business ethics survey. The last survey was conducted in 2013 and ECI’s survey provides important and valuable insights into corporate metrics...more

10 regulatory insights for Canadian risk and compliance

From Anti-Money Laundering (AML) to challenges around cryptocurrencies and cybersecurity, our Regulatory Intelligence experts have identified the top 10 regulatory issues facing Canadian risk and compliance in 2018....more

Paw and Orihuela: The Long Shadow of Odebrecht's Corruption

by Pepper Hamilton LLP on

For over a year, Brazilian federal police could not access the files on Marcelo Odebrecht’s notebook computer. They tried using the password from Marcelo’s cell phones, with no luck. Originally published in The FCPA Blog -...more

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