The Presumption of Innocence Podcast: Episode 45 - The Grit, Grace and Gift of Second Chances
Wicked Coin: The "Fat Leonard" Scandal
Navigating Civil Standing Requirements for Defense Success — RICO Report Podcast
Episode 330 – Halyna Senyk on Anti-Corruption Progress in Ukraine
Managing Corruption Risk in Latin America
The Presumption of Innocence Podcast: Episode 38 - A Blueprint for Compliance: The Fraud Pentagon Theory
Episode 323 - Carlos Villagran Discusses Rebuilding a Corporate Culture After a Crisis
The Presumption of Innocence Podcast: Episode 34 - A Conversation With Jesse Eisinger, Author of 'The Chickenshit Club: Why the Justice Department Fails to Prosecute Executives'
Episode 317 -- A Deep Dive into the Trafigura FCPA Settlement
What's Going on with FCPA?
Episode 316 -- DOJ Announces New Whistleblower Policy
RICO Vicarious Liability — RICO Report Podcast
Episode 313 -- The Coming Criminal Corporate Sanctions Enforcement Storm
RICO Damages — RICO Report Podcast
Corruption, Crime & Compliance: DOJ’s Shifting Approach to Recidivism and Self-Disclosure
Episode 305 -- Deep Dive into SAP FCPA Settlement
AGG Talks: Antitrust and White-Collar Crime Roundup - Developments in the Trump Indictments and Recent Supreme Court Issues
Episode 300 -- Deep Dive into DOJ FCPA Settlement with Two U.K. Reinsurance Companies for Bribery in Ecuador
AGG Talks: Antitrust and White-Collar Crime Roundup - Examining the Latest Updates in the Pending Criminal and Civil Litigation Against Trump
The EU Directive for Combatting Corruption
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
After a long hiatus, the SEC announced a settlement with WPP plc, the world’s largest advertising group, for FCPA violations in India, China, Brazil and Peru for $19.2 million. The SEC’s resolution charges WPP with...more
Beam Suntory, a global producer and distributor of distilled beverages, settled its FCPA case with DOJ for $19.5 million for bribes paid in India. The DOJ settlement follows an SEC FCPA settlement for $8 million announced...more
World Acceptance Corporation (“WAC”), a US-based consumer loan company, agreed to pay the SEC $21.7 million for FCPA violations in Mexico. WAC’s cited violations covered the full gamut of FCPA violations, including bribery...more
The initial FCPA Guidance included valuable compliance program guidance keyed to the heading, “Hallmarks of an Effective Compliance Program.” Issued in 2012, the outline of an effective compliance program was an important...more
Eni S.p.A (Eni) joined the two-time Foreign Corrupt Practices Act (FCPA) loser ranks last week when it agreed to a Cease and Desist Order (Order) with the Securities and Exchange Commission (SEC) for violations of the...more
On March 31, 2020, the U.S. District Court for the Southern District Court of California entered partial summary judgment in Erhart v. BofI Holding, Inc., a prominent, long-running whistleblower lawsuit under the...more
Cardinal Health (“Cardinal”) agreed to pay the SEC $8.8 million for FCPA violations in China relating to its internal controls and books and records. Cardinal acknowledged facts relating to internal controls deficiencies and...more
La Ley de Prácticas Corruptas en el Extranjero (“Foreign Corrupt Practices Act – FCPA”) prohíbe el pago de sobornos a funcionarios extranjeros para ayudar a obtener o retener negocios. Exige que las empresas cuyos valores se...more
The Foreign Corrupt Practices Act (FCPA) prohibits payment of bribes to foreign officials to assist with obtaining or retaining business. It requires companies whose securities are listed in the US to maintain books and...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 standing Foreign Corrupt Practices Act (FCPA) enforcement action involving Telefonaktiebolaget LM Ericsson (Ericsson), a multinational networking and...more
We got a fair bit more clarity on the Cognizant Technologies Solutions Corporation (“Cognizant”) Foreign Corrupt Practices Act (FCPA) last week, when Sridhar Thiruvengadam, the Chief Operating Officer (COO) agreed to settle...more
“Microsoft’s subsidiary in Hungary provided discounts on software licenses to its resellers, distributors and other third parties. Instead of passing on the discounts to Microsoft’s government customers, the discounts were...more
On May 9, 2019, Telefônica Brasil agreed to pay a US$4.13 million civil fine to settle U.S. Securities and Exchange Commission charges for violations of the internal accounting controls and recordkeeping provisions of the...more
Bribery and corruption have long plagued the construction industry, particularly in emerging markets in Latin America, Eastern Europe, the Middle East and Asia-Pacific. ...more
On March 6, 2019, the Securities and Exchange Commission (“SEC”) announced that it was settling allegations that Russian telecommunications company Mobile Telesystems Pjsc (“MTS”) violated anti-bribery, books and records, and...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
Over this two-part blog post series, I have been considering the Stryker Corporation 2018 Foreign Corrupt Practices Act (FCPA) enforcement action brought by the Securities and Exchange Commission (SEC)....more
Last month, Stryker Corporation joined a rather ignominious list of recidivists under Foreign Corrupt Practices Act (FCPA) enforcement annuls....more
Stryker Corporation has suffered a second FCPA enforcement action, and will now bear the stigma of FCPA “recidivist.” In reaching a settlement with the SEC and agreeing to pay a $7.8 million civil penalty, Stryker will now...more
Well, add another pharmaceutical company to the FCPA healthcare “sweep.” Frankly, the term “sweep” makes it sound like a coordinated enforcement effort – instead, it is more accurate to think of it as multiple prosecutions...more
Legg Mason can finally close its books on the Gaddafi-era, Libyan bribery scandal. In June 2018, Legg Mason entered into a non-prosecution agreement with the Justice Department and agreed to pay $32 million for its role in...more
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