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Deferred Prosecution Agreements Department of Justice (DOJ) Compliance

Thomas Fox - Compliance Evangelist

The Boeing Saga: Compliance, Accountability, and the Path Forward

When it comes to corporate accountability few cases are as significant as the ongoing litigation involving Boeing. Since the 737 MAX safety scandal erupted in 2021, the company has been embroiled in a complex legal journey....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

Axinn, Veltrop & Harkrider LLP

Conspiracy Theories Newsletter, 2024 Edition: Eight Predictions for the Future of Cartel Enforcement

2023 was a dramatic year for criminal antitrust enforcement in the United States. The Antitrust Division of the U.S. Department of Justice (“DOJ”) garnered big wins: three convictions at trial,1 $267 million in criminal fines...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

Thomas Fox - Compliance Evangelist

The SAP FCPA Enforcement Action-Part 3: The Comeback

This week we are taking a deep dive into the SAP Foreign Corrupt Practices Act (FCPA) enforcement action. In it, SAP agreed to pay the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) approximately...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

Allen Barron, Inc.

How Does the IRS Use AI to Identify Tax Cheats?

Allen Barron, Inc. on

Could Artificial Intelligence (AI) increase the likelihood of an IRS audit in your future? How does the IRS use AI to identify US taxpayers who attempt to hide assets, under-report income or otherwise cheat the IRS? In...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

ArentFox Schiff

Show Me the Money: Using Compensation Structures to Promote Compliance

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Recent guidance from the US Department of Justice (DOJ) reflects its continued focus on corporate compensation structures to promote compliance. In the past few months, the DOJ has entered into settlement agreements that...more

Harris Beach PLLC

HHS Office of Inspector General August 2023 Enforcement Activity

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The following is a summary of selected federal Department of Health and Human Services’ Office of Inspector General (OIG) reports of fraud and abuse enforcement activity across the country. The enforcement actions reported...more

The Volkov Law Group

Lessons Learned from Ericsson’s DPA Breach: An Internal Investigation Nightmare (Part III of III)

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This is not your typical FCPA enforcement action Lessons Learned column.  Instead, Ericsson’s breach of its DPA presents a laundry list of internal investigation errors – as a practitioner in this area, this is the nightmare...more

The Volkov Law Group

Ericsson’s DPA Breach Conduct – Failures to Disclose and Report (Part II of III)

The Volkov Law Group on

Ericsson’s breach of its 2019 Deferred Prosecution Agreement reads like an internal investigation horror show.  It is every investigator’s nightmare scenario – failure to discover evidence that was available to inform and...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

Thomas Fox - Compliance Evangelist

ABB FCPA Resolution: Part 5 – A Win for Compliance

We conclude our exploration of the latest resolution of a Foreign Corruption Practices Act (FCPA) violation involving the Swiss construction giant, ABB Ltd. There have been several reference documents used this week and they...more

BakerHostetler

DOJ Corporate Compliance Certifications Appear to Be Here to Stay

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The compliance certification policy was first announced by Assistant Attorney General (Assistant AG) Kenneth Polite in March 2022, when he stated that for all criminal division “corporate resolutions (including guilty pleas,...more

Snell & Wilmer

DOJ Updated Corporate Criminal Enforcement Policies

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In a highly anticipated speech, Deputy Attorney General Lisa O. Monaco delivered remarks outlining updates to the U.S. Department of Justice (“DOJ”) perspective on the Corporate Crime Enforcement policy. These updates are the...more

Society of Corporate Compliance and Ethics...

What DAG Lisa Monaco's Speech Means for Compliance Programs

United States Deputy Attorney General (DAG) Lisa Monaco recently gave a speech in which she outlined both new policies at the Department of Justice (DOJ) as well as enhancements to existing ones that can have a profound...more

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