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Deferred Prosecution Agreements Compliance Securities and Exchange Commission (SEC)

Thomas Fox - Compliance Evangelist

2 Gurus Talk Compliance: Episode 26 – The Compliance Week Wrap Up Edition

What happens when two top compliance commentators get together? They talk about compliance, of course. Join Tom Fox and Kristy Grant-Hart in 2 Gurus Talk Compliance as they discuss the latest compliance issues in this week’s...more

BakerHostetler

DOJ to Corporations - “Knock on Our Door Before We Knock on Yours”

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At last week’s ABA National White Collar Crime Institute, the leadership of the Department of Justice (the DOJ or the Department), including Attorney General Merrick Garland and Deputy Attorney General Lisa Monaco, made clear...more

Thomas Fox - Compliance Evangelist

The SAP FCPA Enforcement Action-Part 4: The Fines: Self-Disclose, Self-Disclose, Self-Disclose

We continue our exploration of the SAP Foreign Corrupt Practices Act (FCPA) enforcement action. Today we go full geek in a look at the fine and penalty and most importantly what the fine and penalty communicate about what the...more

Guidepost Solutions LLC

DOJ Maintains Interest in Bribery in Mexico and Latin America

Recent Department of Justice (“DOJ” or “Department”) activity on bribery in Mexico and Latin America sends a warning and provides a roadmap to companies doing business there.  By following the roadmap, companies may escape...more

The Volkov Law Group

SAP Returns to U.S. Enforcement Scene: Pays DOJ and SEC Over $220 Million to Resolve FCPA Violations (Part I of III)

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Life is always filled with surprises.  Just when we thought 2023 was a “slow” FCPA enforcement year, DOJ and SEC announced a large enforcement action against SAP for approximately $220 million for FCPA violations in South...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for November 2023

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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

Paul Hastings LLP

More Clarity on the Horizon for FCPA Resolutions? DOJ and SEC Officials Discuss Enforcement Trends

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On November 28–30, 2023, the American Conference Institute’s 40th International Conference on the Foreign Corrupt Practices Act (“FCPA”), held in Washington, D.C., brought together prosecutors, regulators, corporate...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

HaystackID

Cooperation Standards in Government Investigations: Practical Tips

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Editor’s Note: From time to time, ComplexDiscovery highlights publicly available or privately purchasable announcements, content updates, and research from cyber, data, and legal discovery providers, research organizations,...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

A&O Shearman

DOJ And SEC Extend FCPA Monitorship For Telecom Company

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On December 14, a multinational telecommunications company headquartered in Stockholm, Sweden (the “Company”), announced it had reached agreement with the U.S. Department of Justice (“DOJ”) and Securities and Exchange...more

Thomas Fox - Compliance Evangelist

Danske Bank: Part 4 – The Bank’s Response

We are exploring the Danske Bank A/S (Danske Bank), AML enforcement action in which Danske Bank pled guilty this week and agreed to forfeit $2 billion to resolve the US investigation into its fraud on US banks. According to...more

McGuireWoods LLP

Brazilian Airline to Pay Millions in Coordinated Foreign Bribery Resolution

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On September 15, 2022, GOL Linhas Aéreas Inteligentes S.A. (GOL), Brazil’s second largest domestic airline, resolved long-running parallel investigations by the U.S. Department of Justice (DOJ) and the Securities and Exchange...more

The Volkov Law Group

DOJ and SEC Secure $41 Million Settlement from Brazilian Airline for FCPA Violations (Part I of II)

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The Department of Justice and the Securities and Exchange Commission reached a $41 million settlement with GOL Linhas Aéreas Inteligentes S.A. (“GOL”) to resolve criminal and civil foreign bribery charges....more

Ankura

UK Serious Fraud Office's Annual Report 2021-2022: A Call for Investment

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The UK’s Serious Fraud Office (SFO) recently released its 2021-2022 Annual Report. The report highlights major successes for the SFO along with key challenges the prosecutor needs to tackle going forward....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

Thomas Fox - Compliance Evangelist

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

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

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

Troutman Pepper

DOJ’s Case Against Ericsson Reinforces the Importance of Self-Disclosure for Companies Subject to DPAs and Monitorships

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On March 2, Ericsson, the Swedish networking and telecommunications company, reported that the Department of Justice (DOJ) has accused the company of violating its 2019 Deferred Prosecution Agreement (DPA) by failing to...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

Lowenstein Sandler LLP

Competitor Recovers Damages From FCPA Violator In Post-Enforcement Civil Litigation

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On Wednesday, May 12, 2021, Swedish telecommunications manufacturer Ericsson announced that it had reached an €80 million ($96.66 million) settlement with one of its competitors to compensate for commercial damages the...more

Faegre Drinker Biddle & Reath LLP

Growing International Coordination of Multi-jurisdictional FCPA Enforcements

In remarks at the American Conference Institute’s 37th International Conference on the Foreign Corrupt Practices Act (FCPA) on December 3, 2020, Gen. Brian C. Rabbit, then acting assistant attorney general of the U.S....more

The Volkov Law Group

The Herbalife FCPA Settlement: Board Oversight and Internal Audit Failures

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In the enforcement and compliance arena, there are instances of misconduct that underscore important governance principles. But this just sounds like a bunch of mumbo jumbo (the technical term, I know)....more

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