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Criminal Prosecution Compliance Anti-Corruption

Womble Bond Dickinson

Recent Anti-Corruption Updates

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Two recent court Foreign Corrupt Practices Act (FCPA) cases, a significant amendment to the Foreign Extortion Prevention Act (FEPA), and the new pilot whistleblower rewards program show that Anti-Corruption Enforcement...more

Fox Rothschild LLP

The Presumption of Innocence Podcast: Episode 34 - A Conversation With Jesse Eisinger, Author of 'The Chickenshit Club: Why the...

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In a single decade, the prosecutions of those accused of white-collar crime underwent a radical transformation. This thought-provoking episode will take you back in time to explore the DOJ's approach in the early 2000s Enron...more

Benesch

White Collar Quarterly Report | Q1 2024

Benesch on

We are thrilled to introduce the inaugural issue of our quarterly White Collar newsletter, a dedicated resource from Benesch’s White Collar, Government Investigations & Regulatory Compliance Practice Group. Each issue...more

The Volkov Law Group

Gunvor’s Blockbuster FCPA Settlement: Lessons Learned and Trends (Part III of III)

The Volkov Law Group on

The Department of Justice’s blockbuster FCPA settlement with Gunvor restores the credibility of DOJ’s pronouncements of DOJ’s commitment to aggressive FCPA enforcement.  While I have questioned DOJ’s commitment to its...more

The Volkov Law Group

The Coming Corporate Sanctions Enforcement Storm (Part I of II)

The Volkov Law Group on

There are some things you learn best in calm, and some in storm.  Willa Cather I know I sound like a broken record.  The Justice Department’s white collar criminal enforcement  has been trending down over the last few...more

WilmerHale

SFO Director Nick Ephgrave: The First 100 Days

WilmerHale on

The new SFO Director, Nick Ephgrave QPM, marks his first 100 days in post this month after succeeding Lisa Osofsky in September 2023. Ephgrave has overseen a dynamic start to his tenure with the announcement of three new...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for May 2023

Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption law and enforcement developments from the past...more

The Volkov Law Group

DOJ’s Enforcement and Compliance Changes: Weighing the Pros and Cons of Voluntary Disclosures

The Volkov Law Group on

The Justice Department certainly has altered the landscape of enforcement, compliance priorities, and ultimately corporate decisions surrounding voluntary disclosure.  It has become a little bit more complicated to sort out...more

Skadden, Arps, Slate, Meagher & Flom LLP

New US Efforts To Prosecute Sanctions Evasion and Export Control Violations May Require Compliance Programs To Be Updated

DOJ Increases Resources To Investigate and Prosecute Sanctions Evasion and Export Control Violations - On March 2, 2023, during a keynote speech at the American Bar Association’s annual White Collar Crime National...more

The Volkov Law Group

Ericsson Settles Breach of 2019 FCPA Deferred Prosecution Agreement: Agrees to Plead Guilty, Pay $206 Million, and Extend...

The Volkov Law Group on

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

BakerHostetler

DOJ's Newly Revised Corporate Enforcement Policy Incentivizes Robust Compliance Programs, Cooperation and Remediation

BakerHostetler on

On Jan. 17, AAG Polite announced “the first significant changes” to the CEP since 2017. The policy revisions will apply to all corporate criminal matters handled by the Criminal Division and offer companies “new, significant,...more

Thomas Fox - Compliance Evangelist

Incentives in Compliance: Part 2 – Clawbacks

Just as the Department of Justice (DOJ) has long focused on financial incentives in a best practices compliance program, it has equally focused on punishing those officers and employees who fail to do business ethically and...more

The Volkov Law Group

Lessons Learned and the Big Picture: ABB – the Three-Time Loser – Settles Yet Another FCPA Case (Part III of III)

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The ABB case, like most significant FCPA enforcement actions, sets important precedent and policy reminders. With time, and looking back, ABB gives companies with a prior criminal history a way forward to seek a fair...more

Society of Corporate Compliance and Ethics...

The Sentencing Guidelines at Thirty

The Organizational Sentencing Guidelines have turned thirty, and what began as an experiment is now an established framework for compliance programs in the US and around the globe. To commemorate the milestone, the United...more

Wilson Sonsini Goodrich & Rosati

DOJ Announces New Guidance on Corporate Criminal Enforcement

On September 15, 2022, Deputy Attorney General of the Department of Justice (DOJ) Lisa Monaco announced pivotal new guidance about the DOJ’s corporate criminal enforcement efforts. Her speech, accompanied by a more...more

Thomas Fox - Compliance Evangelist

Would You Buy a New Car From Them? Part 2 – Lessons for Compliance

Over this series, I am reviewing the corruption enforcement action Involving the company formerly known as Chrysler Group LLC, now FCA US LLC (Chrysler or the company herein) which was criminally sentenced to pay a fine of...more

Guidepost Solutions LLC

The Sky Will Not Fall with New Justice Department CEO / CCO Certifications; Instead, the Sun Will Shine

Despite an industry uproar, the sky is NOT falling with the U.S. Department of Justice (“DoJ”) requirement that chief executive officers (“CEOs”) and chief compliance officers (“CCOs”) certify that their compliance programs...more

The Volkov Law Group

DOJ Compliance Program Certification Requirements (Part I of III)

The Volkov Law Group on

The Department of Justice continues to respond to the compliance community’s concerns about the new certification requirement adopted as part of the Glencore FCPA enforcement action.  DOJ has adopted this new requirement to...more

The Volkov Law Group

The Glencore Settlement: Lessons Learned (Part V of V)

The Volkov Law Group on

The Justice Department has resumed FCPA enforcement with a bang.  The new enforcement approach has been unveiled and the message for CCOs and corporate business leaders is clear — anti-corruption compliance should be a...more

The Volkov Law Group

Gleaning the Inside of the Human Mind and Criminal “Intent”

The Volkov Law Group on

Prosecuting white collar crimes is a “mind game” in more ways than one.  This is another in my long series of profound grasps of the obvious. - As a former federal prosecutor, the difference between a crime and compliant...more

The Volkov Law Group

You Win Some and You Lose Some:  DOJ’s Stumbles and Mixed Bag of Criminal Trial Results (Part I of III)

The Volkov Law Group on

Federal prosecutors know that their job – to represent the United States – is the highlight of their legal career. Speaking from experience, federal prosecutors are a privileged lot – they can announce in court they represent...more

WilmerHale

Análisis Anual sobre Prácticas Anticorrupción en América Latina: Desarrollos del 2021 y Predicciones para el 2022

WilmerHale on

Aunque la cantidad de casos relacionados con la Ley de Prácticas Corruptas en el Extranjero (Foreign Corrupt Practices Act, FCPA) resueltos públicamente en el año 2021 fue relativamente baja en comparación con los años...more

WilmerHale

Latin America Anti-Bribery Year-in-Review: 2021 Developments and Predictions for 2022

WilmerHale on

Although the number of publicly resolved Foreign Corrupt Practices Act (FCPA) cases in 2021 was relatively low compared to prior years, enforcement actions related to Latin America played a particularly prominent role. Many...more

Morgan Lewis

DOJ Ramping Up Fraud Enforcement Efforts: 2021 Year in Review Report

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The US Department of Justice’s Criminal Division Fraud Section released its annual Year in Review report on February 15, covering 2021. Despite ongoing aftershocks associated with the global pandemic, this year’s report...more

Jones Day

FCPA 2021 Year In Review

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The Biden administration took office in January 2021, announcing aggressive and sweeping anticorruption initiatives to tackle corruption around the world, labeling corruption a national security priority, and signaling a...more

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