Podcast - Risk Management: Revised FCPA Corporate Enforcement Policy
This Week in FCPA-Episode 80, The Last Jedi Edition
FCPA Compliance Report-Episode 346, Mike Skopets on Miller’s Summer 2017 FCPA Report
FCPA Compliance Report-Episode 345-Mike Volkov on Linde Gas and CDM Smith declinations
This Week in FCPA-Episode 58, the Declination Edition
Compliance into the Weeds-Episode 43, the Linde Declination
This Week in FCPA-Episode 56
FCPA Pilot Program
Everything Compliance-Episode 11, the first 100 Days of the Trump Administration, Part II
FCPA Compliance Report-Episode 325, Miller & Chevalier Report on Declinations
Earlier this month, DOJ updated its Corporate Enforcement Policy (CEP). Aimed at encouraging companies to voluntarily disclose unlawful conduct, the updated CEP gives greater opportunities to companies to avoid charges...more
On January 17, 2023, Assistant Attorney General Kenneth A. Polite, Jr. (AAG Polite) announced changes to the Department of Justice’s (DOJ) FCPA Corporate Enforcement Policy (CEP). The CEP, which applies to all Criminal...more
DOJ closed out its FCPA enforcement year in 2022 with two significant settlements, the ABB and Honeywell cases. Aside from these two big settlements, there was a flurry of other actions in the last quarter of 2022....more
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
In a recently released letter, the Justice Department issued a declination to the Insurance Corporation of Barbados Limited (ICBL) for violations of the FCPA under the FCPA Corporate Enforcement Policy. DOJ required ICBL to...more
We had three major Foreign Corrupt Practices Act (FCPA) cases resolved in Q2 2018. They all reached different resolutions under the new FCPA Corporate Enforcement Policy and the new anti-piling on policy....more
In this episode, I visit with Mike Skopets, from Miller & Chevalier on the firm’s Summer 2017 FCPA Report. We discuss the background to the Report and begin with what macro trends the firm identified. We discuss the numbers...more
On June 30, 2017, the Department of Justice (“DOJ”) announced that it had declined to bring charges against and was closing its investigation into CDM Smith Inc. (“CDM”), a Boston-based engineering and construction group, for...more
Welcome to Dorsey & Whitney’s monthly Anti-Corruption Digest. The Digest puts material regarding anti-corruption enforcement from around the world at your fingertips, keeping you ahead of critical events that impact global...more
The Justice Department recently resolved two separate FCPA investigations under its Pilot Program. To be sure, DOJ’s resolution of these two matters reinforces the real and tangible benefits of its Pilot Program....more
The U.S. Department of Justice (DOJ) on June 16, 2017, announced its first declination of 2017 and the closing of its investigation of Linde North America Inc. and Linde Gas North America LLC (collectively, Linde) concerning...more
This week, Jay and I have a wide-ranging discussion on some of the week’s top compliance related stories. We discuss: 1. The Kokesh case at the US Supreme Court is significant for SEC enforcement of the FCPA around profit...more
Enforcement of the Foreign Corrupt Practices Act (FCPA) remained a high priority for the Department of Justice and the Securities and Exchange Commission in 2016, resulting in more than 50 combined enforcement actions, record...more
ANTICORRUPTION DEVELOPMENTS – DOJ Issues First-Ever Declinations Requiring Disgorgement of Profits to Resolve FCPA Violations - On September 29, 2016, the Department of Justice (DOJ) for the first time announced...more
Breaking new ground, the Department of Justice (DOJ) recently issued two “declinations with disgorgement” to two companies accused of Foreign Corrupt Practices Act (FCPA) violations. These declinations, released under the...more
Last week there were two declinations issued by Department of Justice (DOJ) for Foreign Corrupt Practices Act (FCPA) matters. The matters involved two Texas based, privately held companies. The first was HMT LLC (HMT) which...more
Tom Fox and I recorded a podcast recently on the Johnson Controls enforcement action. In our podcast we discuss a number of issues relating to the Justice Department’s decision to reward Johnson Controls with a declination....more
I continue my review of the Johnson Controls, Inc. (JCI) Foreign Corrupt Practices Act (FCPA) enforcement action today by focusing on the Department of Justice’s (DOJ’s) Declination to Prosecute. Yesterday, I considered the...more
On April 5, 2016, the Fraud Section of the Department of Justice's (DOJ) Criminal Division issued an enforcement plan and guidance (the Guidance) laying out three steps it is taking to intensify Foreign Corrupt Practices Act...more