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
Continuing its focus on incentivizing prompt and voluntary self-disclosure of criminal misconduct, Deputy Attorney General Lisa Monaco announced earlier this month a new U.S. Department of Justice (DOJ) Safe Harbor Policy...more
Deputy Attorney General Lisa Monaco announced a new safe harbor policy for voluntary self-disclosures made in connection with mergers and acquisitions on Wednesday. Pursuant to this new policy, the DOJ will not prosecute...more
Over the last two years, the Department of Justice (DOJ) has announced numerous policy changes on corporate criminal enforcement policies, which were largely based on a self-described “carrot and sticks” approach (“a mix of...more
The U.S. Department of Justice (DOJ), through Assistant Attorney General Kenneth A. Polite Jr., announced on Jan. 17, 2023, "the first significant changes" to its Corporate Enforcement Policy (CEP) since 2017. The revisions...more
Enforcement activity reached new heights in 2019. The year saw the two largest corporate resolutions in the history of the FCPA, corporate penalties paid to US enforcement agencies topped last year’s record levels, and...more
On November 20, 2019, the US Department of Justice (DOJ) announced the latest revisions to the Foreign Corrupt Practices Act Corporate Enforcement Policy (the Corporate Enforcement Policy). The revised language provides...more
Despite predictions of a slow-down in enforcement under the Trump administration—and indications that enforcement in some areas has decreased in the past year1—2018 was yet again an active year for FCPA enforcement. The year...more
On November 29, 2017, Deputy Attorney General Rod Rosenstein delivered remarks at the 34th International Conference on the Foreign Corrupt Practices Act (“FCPA”), in which he announced a revised FCPA Corporate Enforcement...more
The revised FCPA Corporate Enforcement Policy signals DOJ’s emphasis on corporate voluntary self-disclosure, rewarding cooperating companies with a presumption in favor of declination and reductions in penalties. ...more
When a company learns that an employee or third-party business partner may have bribed a foreign official, it is never an easy question as to whether the company should turn itself in to the U.S. government. On November 29,...more
On November 29, 2017, “[d]ue to the unique issues presented in FCPA matters,” Deputy Attorney General Rod Rosenstein announced a new FCPA corporate enforcement policy published in a revision to the United States Attorneys'...more
In this second of a two-part series, we conclude the panel’s discussion of the first 100 days of the Trump administration as it relates to compliance. This episode concludes with the panelists’ rants. 1. Matt Kelly opens...more
When it comes to lawyers, there is no middle ground – you either love them or you hate them. When the government launches an FCPA investigation of a company, lawyers are drawn for two separate functions – to rescue the...more
We are pleased to share with you BakerHostetler's 2013 Mid-Year Foreign Corrupt Practices Act Update, which offers a summary of the following: - Company prosecutions; - Declinations; - Completed trials; ...more