News & Analysis as of

Deferred Prosecution Agreements Cease and Desist Orders

Thomas Fox - Compliance Evangelist

The Herbalife FCPA Enforcement Action: Part 4 – Final Thoughts

We are the end of my multi-part exploration of the Herbalife Nutrition Ltd (Herbalife) Foreign Corrupt Practices Act (FCPA) enforcement action with both the Department of Justice (DOJ) and Securities and Exchange Commission...more

Thomas Fox - Compliance Evangelist

The Herbalife FCPA Enforcement Action: Part 3 – Penalty Calculation and No Monitor

Herbalife Nutrition Ltd (Herbalife) recently concluded a long running Foreign Corrupt Practices Act (FCPA) enforcement action with both the Department of Justice (DOJ) and Securities and Exchange Commission (SEC). Herbalife...more

Thomas Fox - Compliance Evangelist

The Herbalife FCPA Enforcement Action: Part 2 – Bribery Schemes and Numbers

Herbalife Nutrition Ltd (Herbalife) recently concluded a long running Foreign Corrupt Practices Act (FCPA) enforcement action with both the Department of Justice (DOJ) and Securities and Exchange Commission (SEC). Herbalife...more

Thomas Fox - Compliance Evangelist

Wells Fargo Settlement: Part 1 – It’s Even Worse Than Imagined

I did not think that the Wells Fargo fraudulent accounts scandal could get worse for the bank. Boy was I wrong. Last week, in a Press Release, the Department of Justice (DOJ) announced a that Wells Fargo & Company and its...more

Ballard Spahr LLP

SDNY Unveils First Criminal Prosecution of Broker-Dealer for Violating BSA

Ballard Spahr LLP on

For the first time, a broker-dealer, Central States Capital Markets, LLC (Central States), has been prosecuted for violating the Bank Secrecy Act (BSA). ...more

Thomas Fox - Compliance Evangelist

The NPA; The Petrobras FCPA Enforcement Action: Part III

This blog post concludes my multi-part exploration of the Petróleo Brasileiro S.A. – Petrobras (Petrobras) Foreign Corrupt Practices Act (FCPA) enforcement action. Today we consider the stunning result achieved by Petrobras –...more

Thomas Fox - Compliance Evangelist

Panasonic FCPA Enforcement Action: Part I – Background

Those bemoaning the lack of Foreign Corrupt Practices Act (FCPA) enforcement activity can cease. With the Dun & Bradstreet Inc. (D&B) declination last week and this week’s enforcement action involving Panasonic Avionics...more

Thomas Fox - Compliance Evangelist

The Telia FCPA Resolution, Part I

While the resolution of the Telia Company (Telia) Foreign Corrupt Practices Act (FCPA) matter has long been awaited, the results announced yesterday by the Department of Justice (DOJ) and Securities and Exchange Commission...more

Thomas Fox - Compliance Evangelist

First ‘Trial of the Century’ and the SQM FCPA Enforcement Action – Part II

Today I conclude my two-part series on the recent Foreign Corrupt Practices Act (FCPA) enforcement action involving the Chilean chemicals and mining company Sociedad Química y Minera de Chile (SQM), which agreed to pay a...more

Thomas Fox - Compliance Evangelist

A ‘Most Daring Act’ and the SQM FCPA Enforcement Action – Part I

A most “daring act” seems to be a good way to introduce a multi-part look at the recent Foreign Corrupt Practices Act (FCPA) enforcement action involving the Chilean chemicals and mining company Sociedad Química y Minera de...more

The Volkov Law Group

T’Was the Week After Christmas: General Cable and Mexico Aviation FCPA Prosecutions

The Volkov Law Group on

You know this has been a big year in FCPA enforcement when DOJ and the SEC announce two FCPA settlements during the usually sleepy week between Christmas and New Years. And what a year it has been – more to follow in my...more

Thomas Fox - Compliance Evangelist

JPMorgan Sons and Daughters FCPA Enforcement Action, Part II

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

Thomas Fox - Compliance Evangelist

LATAM/LAN FCPA Enforcement Action, Part I-Some Questions

What is the cost of a Foreign Corrupt Practices Act (FCPA) violation? One subset of that question is what is the cost of not cooperating and not remediating during the pendency of such investigations? Those were two of the...more

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