SBR-Author’s Podcast: The Unseen Life of an Undercover Agent: A Conversation with Charlie Spillers
Daily Compliance News: May 21, 2025, The I Want You Back Edition
Daily Compliance News: May 20, 2025, The What Could Go Wrong Edition
Daily Compliance News: May 19, 2025, The Definition of Corruption Edition
Compliance into the Weeds: Leaving on a (Qatari) Jet Plane
The Presumption of Innocence Podcast: Episode 61 - A Call to Service: From Public Duty to Spiritual Advocacy
Daily Compliance News: May 12, 2025, The Corruption in the Broad Daylight Edition
10 For 10: Top Compliance Stories For the Week Ending May 10, 2025
Daily Compliance News: May 8, 2025, The $1MM for a Pardon Edition
Daily Compliance News: May 5, 2025, The Washing Edition
Daily Compliance News: May 1, 2025, The 100 Days of Corruption Edition
10 For 10: Top Compliance Stories For the Week Ending April 26, 2025
Daily Compliance News: April 21, 2025, The Tribute to Pope Francis Edition
Daily Compliance News: April 15, 2025, The Redefining Corruption Edition
Daily Compliance News: April 14, 2025, The Cascade of Corruption Edition
10 For 10: Top Compliance Stories For the Week Ending April 12, 2025
Daily Compliance News: April 10, 2025, The Dark Money Corruption Edition
Daily Compliance News: April 9, 2025, The Corruption at the DOJ Edition
Daily Compliance News: April 8, 2025, The End of Monitors Edition
Daily Compliance News: April 7, 2025, The Whistleblowers Awarded Edition
We have previously written about the impact of the pause in enforcement of the FCPA implemented by the Trump Administration on non-American companies.1 Although the 180-day review period the Executive Order provided to the...more
Anti-bribery and corruption agencies in the UK, France and Switzerland today announced a shared commitment to tackling international bribery and corruption, by way of a new taskforce intended to strengthen collaboration....more
On February 5, 2025, US Attorney General (AG), Pam Bondi, issued a memorandum entitled Total Elimination of Cartels and Transnational Criminal Organizations, in which she provides new guidance to the Department of Justice...more
Newly Appointed US Attorney General Pam Bondi issued a directive shifting the focus of Foreign Corrupt Practices Act investigations and cases away from those that do not involve criminal operations of cartels and...more
On May 10, 2024, Romy Andrianarisoa, former Chief of Staff to the President of Madagascar, was convicted for soliciting bribes from Gemfields Group Ltd (Gemfields), a UK-based mining company specializing in rubies and...more
The Development: After an interruption during the COVID-19 pandemic, authorities across the Asia-Pacific region have fully revived dawn raids....more
In the first major action of 2024, the Department of Justice (DOJ) announced it had entered into a three-year deferred prosecution agreement (DPA) with a publicly traded global software company for alleged violations of the...more
This week we are taking a deep dive into the SAP Foreign Corrupt Practices Act (FCPA) enforcement action. In it, SAP agreed to pay the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) approximately...more
When it comes to FCPA enforcement and expectations, DOJ has moved the goalposts. Some would argue that DOJ has been consistent all along. The truth, like most issues, lies somewhere between the extremes....more
The Justice Department’s FCPA enforcement record for 2024 was slow. This trend was unexpected, contrary to my own predictions and of various other prognosticators. It is hard to explain why this slowdown occurred....more
While the Department of Justice (DOJ) has initiated at least two new Foreign Corrupt Practices Act (FCPA) enforcement actions against U.S. companies, it has also announced several decisions not to prosecute—most recently...more
Ericsson, a multinational telecommunications company, based in Sweden, settled its breach of its 2019 Deferred Prosecution Agreement, agreed to enter a guilty plea and pay a $206 million penalty. In 2019, Ericsson entered...more
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
While Foreign Corrupt Practices Act (FCPA) enforcement activity has not come close to returning to the heights seen a few years ago, 2022 reflected significant increases from the prior year in both the number of cases against...more
The Foreign Corrupt Practices Act (FCPA) (15 U.S.C. § 78dd-1 et seq.) is a federal anti-bribery law that makes it unlawful for certain people to pay foreign government officials in order to conduct business abroad. While it...more
The corruption risks of the telecommunications sector are too often given cursory consideration as, historically, there has been a keener focus on the extractive and energy sectors. Those sectors are considered to have a much...more
Morrison & Foerster’s Automotive Task Force represents automotive industry clients in their most significant legal matters. We have tapped our multidisciplinary Automotive Task Force to get their opinions on what is likely...more
The SEC announced its first FCPA enforcement action in 2022. South Korean telecommunications company, KT Corporation, agreed to pay $6.3 million to settle FCPA violations. As part of the settlement, KT Corp. agreed to pay...more
On January 21, 2022, the Department of Justice (“DOJ”) issued a Foreign Corrupt Practices Act (“FCPA”) Opinion Procedure Release (the “OPR” or “OPR 22-01”) addressing the rarely discussed extortion exception to the FCPA’s...more
A. Basic Overview of Statute - The Foreign Corrupt Practices Act of 1977, as amended, 15 U.S.C. §§ 78dd-1, et seq. (FCPA), makes it unlawful for U.S. persons and entities and others who act within the jurisdiction of the...more
Due to the impact of the COVID-19 pandemic, and the change in presidential administrations in the United States in January 2021, US enforcement of the Foreign Corrupt Practices Act (FCPA) declined in 2021. However, we...more
Scores of articles and volumes of commentary have been issued since President Joseph R. Biden, Jr. issued a presidential memorandum (hereinafter, “Memorandum”) making global anticorruption efforts an urgent national security...more
As the Biden Administration commits to crack down on corruption, recent enforcement actions show the DOJ continues a longstanding trend of relying on AML laws and other alternate statutes to prosecute corruption cases, with...more
The Justice Department and the Securities Exchange Commission are back in business. The first corporate FCPA enforcement action in 2021 came after a six-month hiatus in 2021. While many commentators sought to read the...more
In recent months, the U.S. Department of Justice (DOJ) and Securities & Exchange Commission (SEC) have announced several notable penalties for violations of the U.S. Foreign Corrupt Practices Act (FCPA). The FCPA prohibits...more