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
Daily Compliance News: April 2, 2025, The All WSJ Edition
Daily Compliance News: March 26, 2025, The Missile Strike on Boeing Edition
Daily Compliance News: March 24, 2025, The ABC Task Force Edition
Episode 360 -- Natalie Druckman from Certa on AI-Enhanced Third-Party Risk Management
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
As Saudi Arabia emerges as a global investment destination, it is essential for foreign investors, financial institutions, and legal and compliance professionals to understand the Kingdom’s anti-corruption initiatives,...more
What happens when an entire era of anti-corruption enforcement is put on pause? Is this a strategic move to bolster American businesses or a dangerous rollback of corporate accountability? In an unprecedented move, the...more
On February 11, 2025, Transparency International (TI) published its annual Corruption Perceptions Index (CPI) for 2024. TI observes that corruption remains “a dangerous problem in every part of the world, but change for the...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
Australia has a zero-tolerance approach to corruption, and this policy knows no border or nationality. Bribery or attempts to bribe foreign public officials are considered severe crimes, as mentioned in division 70 of the...more
An amendment to South Africa’s Prevention and Combating of Corrupt Activities Act (PRECCA) in April 2024 has created a new criminal offense relating to the failure by members of the private sector or state-owned entities...more
Earlier this year, Australia enacted the Crimes Legislation Amendment (Combatting Foreign Bribery) Act 2024 (the Act) in an attempt to strengthen the country’s anti-bribery and corruption regime. The Act, which overhauls...more
Six months after the passage of the Crimes Legislation Amendment (Combatting Foreign Bribery) Act 2024, the Australian government has published important guidance on the “adequate procedures” companies should have in place in...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
In Snyder v. United States, the Supreme Court of the United States held that it is not a federal crime for state and local officials to accept gratuities under 18 U.S.C. § 666. In so doing, the Court overturned the decision...more
2024 represents the 25th anniversary of the Organisation for Economic Co-operation and Development (OECD) Convention on Combating Bribery of Foreign Public Officials, which has now been signed by 46 countries—including eight...more
FEPA contains a broad prohibition on corrupt activity and applies to a broad category of public officials. First, FEPA makes it unlawful for any foreign official to “demand, seek, receive, accept, or agree to” receive...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
After the internal report comes in and you have properly triaged the matter, you need to scope out and investigate it, promptly, thoroughly and with competent personnel. In the 2023 ECCP, provided these series of questions...more
China’s anti-corruption laws have been stringent for many years. On 1 January 1980, the Criminal Law of the People’s Republic of China (the “PRC Criminal Law”) containing the criminal offences of bribery and corruption came...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
On December 14, 2023, Congress passed the Foreign Extortion Prevention Act (“FEPA”) in an effort to address certain deficiencies inherent in the current iteration of the Foreign Corrupt Practices Act (“FCPA”), as part of the...more
2023 was a very significant year for every compliance practitioner and compliance program. While there was a paucity of corporate enforcement actions under the Foreign Corrupt Practices Act (FCPA), there were significant...more
Last week at the 40th American Conference Institute (ACI) International Conference on the FCPA, government enforcement agencies such as the Department of Justice (DOJ), Securities and Exchange Commission (SEC), and UK Serious...more
UN Corruption Convention’s Ratification - In October 2003, the General Assembly officially ratified the United Nations Convention against Corruption (“Corruption Convention”). Since that time, a total of 190 countries have...more