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Criminal Penalties Securities and Exchange Commission (SEC)

Smith Debnam Narron Drake Saintsing & Myers,...

What Small Businesses Need to Know About the Corporate Transparency Act

If you are operating a small business and have not educated yourself about the Corporate Transparency Act (“CTA”) requirements that became effective on January 1, 2024, now would be a good time to pay attention. Knowing the...more

Jones Day

FCPA 2023 Year in Review

Jones Day on

Foreign Corrupt Practices Act (“FCPA”) enforcement continues to slowly rebound from pre-pandemic levels. In 2023, the Department of Justice (“DOJ”) and the Securities and Exchange Commission (“SEC”) resolved 13 corporate FCPA...more

Oberheiden P.C.

Ten Key Facts about SEC Investigations for CEOs and In-House Counsel

Oberheiden P.C. on

The U.S. Securities and Exchange Commission (SEC) investigates publicly-traded and privately-held companies for a broad range of statutory and regulatory violations. SEC investigations can target issues ranging from...more

Thomas Fox - Compliance Evangelist

Profit Sharing as Bribery: The Honeywell FCPA Enforcement Action: Part 3 – The Comeback

To close out 2022 in Foreign Corrupt Practices Act (FCPA) enforcement actions, the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) announced settlements of FCPA enforcement actions with Honeywell UOP,...more

Thomas Fox - Compliance Evangelist

Profit Sharing as Bribery: The Honeywell FCPA Enforcement Action: Part 2 – The King and Bribery Schemes

To close out 2022 in Foreign Corrupt Practices Act (FCPA) enforcement actions, the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) announced settlements of FCPA enforcement actions with Honeywell UOP,...more

Thomas Fox - Compliance Evangelist

Profit Sharing as Bribery: The Honeywell FCPA Enforcement Action: Part 1 – Introduction

To close out 2022 in Foreign Corrupt Practices Act (FCPA) enforcement actions, the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) both announced settlements of FCPA enforcement actions with Honeywell...more

Bass, Berry & Sims PLC

FCPA Enforcement Update: Two Big Settlements to End the Year 

Bass, Berry & Sims PLC on

In the past several years there has been a significant decrease in Foreign Corrupt Practices Act (FCPA) enforcement efforts. Reports suggest that corporate criminal cases have decreased by roughly 50% since 2012. FCPA...more

Thomas Fox - Compliance Evangelist

Cookies, Chocolates and IP: The Stericycle FCPA Enforcement Action – Part IV

Last week, the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) announced a Foreign Corrupt Practices Act (FCPA) enforcement action, involving the waste management company, Stericycle, Inc....more

McGuireWoods LLP

DOJ and SEC Kick Off the Second Quarter with Major FCPA Settlement with International Waste Management Company

McGuireWoods LLP on

On April 20, 2022, the U.S. Department of Justice (DOJ) and Securities and Exchange Commission (SEC) separately announced that Stericycle Inc. (Stericycle), an international waste management company headquartered in Lake...more

Thomas Fox - Compliance Evangelist

Cookies, Chocolates and IP: The Stericycle FCPA Enforcement Action – Part I

The Department of Justice (DOJ) and Securities and Exchange Commission (SEC) announced a Foreign Corrupt Practices Act (FCPA) enforcement action. To say that the respondent company, Stericycle, Inc. (Stericycle) had a culture...more

Goodwin

2021 Year in Review: FCPA

Goodwin on

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

Thomas Fox - Compliance Evangelist

2021 – The Year in FCPA Enforcement

There was a paucity of Foreign Corrupt Practices Act (FCPA) enforcement actions in 2021. However, the few enforcement actions announced did provide significant lessons for every compliance professional....more

Perkins Coie

AMLA 2020 Series Part 2: New Bank Secrecy Act Whistleblower Provisions

Perkins Coie on

On New Year’s Day 2021, Congress passed the Anti-Money Laundering Act of 2020 (AMLA 2020). As we reported last April, the AMLA 2020 included sweeping reforms aimed at strengthening protections against money laundering,...more

Thomas Fox - Compliance Evangelist

Panasonic Avionics Whistleblower Award

Last week a major Securities and Exchange Commission (SEC) whistleblower award of $28 million was announced (SEC Award). Although the names of the parties were redacted, the law firm which represented the whistleblower...more

ArentFox Schiff

Investigations Newsletter: French Concrete Contractor to Pay $3.9 Million FCA Penalty

ArentFox Schiff on

French Concrete Contractor to Pay $3.9 Million FCA Penalty - On February 17, 2021, the Department of Justice (DOJ) announced that a French company, COLAS Djibouti SARL, agreed to pay $3.9 million to resolve allegations...more

ArentFox Schiff

Deutsche Bank DPA Reflects Government’s Focus on Third-Party Risk Management and Data-Driven Compliance Programs

ArentFox Schiff on

On January 8, 2021, US authorities announced that they reached an agreement with Deutsche Bank Aktiengesellschaft (Deutsche Bank) to resolve the government’s investigation into violations of the Foreign Corrupt Practices Act...more

ArentFox Schiff

Investigations Newsletter: Investment Bank To Pay Over $130 Million To Resolve Foreign Corrupt Practices Act and Fraud Allegations

ArentFox Schiff on

Deutsche Bank to Pay Over $130 Million to Resolve Foreign Corrupt Practices Act and Fraud Allegations - Deutsche Bank Aktiengesellschaft (Deutsche Bank) has agreed to pay more than $130 million to resolve the government’s...more

Bass, Berry & Sims PLC

FCPA Update: Enforcement Continues

Bass, Berry & Sims PLC on

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

Holland & Knight LLP

Key Provisions of the Anti-Money Laundering Act of 2020

Holland & Knight LLP on

The Anti-Money Laundering Act of 2020 (AMLA 2020) became law on Jan. 2, 2020, when Congress overrode President Donald Trump's veto of the National Defense Authorization Act. AMLA 2020 is the most consequential anti-money...more

Society of Corporate Compliance and Ethics...

JPMorgan pays record fine for 'spoofing'

CEP Magazine (December 2020) - The United States Department of Justice (DOJ) and the U.S. Securities and Exchanges Commission announced a deferred prosecution agreement with JPMorgan Chase & Co., including a fine of $920...more

Thomas Fox - Compliance Evangelist

J&F - The Plea Agreement

Today, I continue a multi-part exploration of one world’s largest anti-corruption enforcement actions, the J&F Investimentos SA (J&F) matter. It involved huge fines and penalties in both Brazil and the United States. In the...more

Skadden, Arps, Slate, Meagher & Flom LLP

OMB Announces Best Practices for Regulatory Enforcement and Adjudication

On August 31, 2020, the Office of Information and Regulatory Affairs (OIRA), within the Office of Management and Budget (OMB), issued a memorandum to all executive departments and agencies on reforming regulatory enforcement...more

ArentFox Schiff

JPMorgan Chase DPA Provides Insight into Government’s Assessment of Compliance Programs

ArentFox Schiff on

On September 29, 2020, US authorities announced that they reached an agreement with JPMorgan Chase & Co. (JPMorgan Chase) to settle criminal charges related to two distinct years-long market manipulation schemes involving...more

SECIL Law

Double Enforcers, Double Penalties, Double Jeopardy, and Double Talk

SECIL Law on

On July 14, 2020, in the case of United States v. Bank, the U.S. Court of Appeals for the Fourth Circuit answered its own rhetorical question: “[W]hether disgorgement ordered in a civil [SEC] proceeding constitutes a...more

Oberheiden P.C.

A CEO's Guide to FCPA Compliance

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- A tone-at-the-top business culture with CEO leadership is a critical component of effective anti-corruption and anti-bribery policy implementation. - CEO leadership helps set an example for lower management and company...more

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