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
Episode 295 -- Deep Dive into the Albemarle DOJ and SEC FCPA Settlements
Yesterday’s jobless numbers were down a bit from a week earlier but still topped 800,000 for the 4th week in a row. “Claims remain above the pre-pandemic peak of 695,000 and are higher than in any previous recession for...more
JP Morgan Chase (“JP Morgan”) is not having a positive year when it comes to government enforcement. JP Morgan is at the brink of a multi-billion dollar FCPA settlement for its involvement in the 1MDB corruption scandal in...more
Volatility’s the name of the game again, folks, and we have COVID-19 to thank. Just a day after markets jumped in response to central bank and Super Tuesday news, the dove again some 3% as virus-related fears took hold again....more
More than a bit of drama in the auto world yesterday, with General Motors suing rival Fiat Chrysler, accusing it of “bribing United Auto Workers officials to gain competitive advantages in contract negotiations.” The UAW’s...more
One of the complaints still made about the Department of Justice (DOJ) is that companies are not made aware of the requirements of a best practices compliance program. ...more
The Treasury Department’s Office of Foreign Asset Control (“OFAC”) announced its third enforcement action for 2018. While OFAC has been busy with implementing new sanctions regimes and re-imposing the Iran sanctions regime,...more
A company that commits bribery has to undergo a soul-searching examination of its operations, from top to bottom. Bribery violations come in all shapes and forms – systemic violations like Siemens, Daimler and other...more
We begin the New Year with a three-part series on the FCPA: (1) A review of FCPA enforcement in 2016; (2) Trends from 2016 FCPA enforcement; and (3) Predictions for FCPA enforcement in 2017....more
Bribery and corruption remained a prominent fixture of media headlines throughout 2016, competing with the UK referendum on membership of the European Union, the Panama Papers leaks, and the continued activity of terrorist...more
There is no question that the Justice Department has raised compliance program expectations in a number of areas. Whatever you may think about the efficacy or fairness of the FCPA Pilot Program, the Justice Department has...more
This week I am exploring the JP Morgan Chase (JPM) and its subsidiary, JPMorgan Securities (Asia Pacific) Limited (JPM-APAC), (collectively ‘the company’) Foreign Corrupt Practices Act (FCPA) enforcement action which...more
Today I will consider the superior result achieved by JPM in its FCPA resolution. Not only did it receive a 25% discount off the bottom of the US Sentencing Guidelines fine range but it received a NPA and not even a Deferred...more
JP Morgan Chase (JPM) and its subsidiary, JPMorgan Securities (Asia Pacific) Limited (JPM-APAC) resolved its Foreign Corrupt Practices Act (FCPA) matter last week, obtaining a Non-Prosecution Agreement (NPA) from the...more
On the Hill yesterday, Fed Chair Yellen acknowledged that the recent election would likely mean changes for the economy, but she said it was “too soon” to predict the nature of that economic impact at this time (though that...more
One of the top academic commentators in the anti-corruption space is Matthew C. Stephenson, co-founder of the Global Anticorruption Blog. I was intrigued by Stephenson’s piece, entitled “Does an FCPA Violation Require a Quid...more
I begin today’s post with a tip of the (cycling) helmet to Englishman Chris Froome who yesterday won his third Tour de France championship. Froome overcame a great many obstacles, not the least of which was being involved a...more
Some people are gluttons for punishment. We all know people in our professional and personal lives who repeatedly end up in trouble. Even when they escape some serious consequence or problem, they inevitably bring about...more
You never see the words “poor” and “JP Morgan” in the same sentence. It is a historical oxymoron – the words do not fit together. However, if you have been following the headlines lately – you have to think to yourself,...more