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Deferred Prosecution Agreements Internal Controls

Thomas Fox - Compliance Evangelist

The Boeing Plea Agreement-A Major Disconnect

In its proposed Plea Agreement, the Department of Justice (DOJ) lays out the abject failures of Boeing which led the DOJ to conclude the underlying Deferred Prosecution Agreement (DPA) from 2021 has been breached. The DOJ...more

Thomas Fox - Compliance Evangelist

The Boeing Monitorship – Compliance, Accountability, and the Path Forward

When it comes to corporate accountability and the often murky waters of compliance, few cases are as illustrative and significant as the ongoing litigation involving Boeing. Since the 737 MAX safety scandal erupted in 2021,...more

The Volkov Law Group

Boeing’s Failure to Integrate Compliance Anti-Fraud Controls with Quality and Safety Functions (Part III of III)

The Volkov Law Group on

Boeing’s Plea Agreement includes two Separate Factual Statements — the January 7, 2021 DPA, which is discussed in a prior blog post, and a factual outline of Boeing’s breach of the original DPA, resulting in the current Plea...more

The Volkov Law Group

Deep Dive into Proposed Boeing Plea Agreement (Part II of III)

The Volkov Law Group on

DOJ and Boeing have entered into a proposed plea agreement that will require judicial scrutiny and determinations of the public interest and the victims’ rights under the Crime Victims’ Rights Act, 18 U.S.C. § 3771 [“CVRA”]. ...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for November 2023

Morrison & Foerster LLP on

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

American Conference Institute (ACI)

DOJ CCO Certification Requirement Will Up the Ante of CCO Oversight

Officials with the U.S. Department of Justice have portended a sea change in the oversight responsibilities of chief compliance officers (CCOs) as it concerns corporate resolutions going forward. In public remarks made March...more

The Volkov Law Group

SEC Joins DOJ in Probe of Ericsson ISIS Bribery Payments

The Volkov Law Group on

Ericsson is having a tough time.  First, in 2019, Ericsson settled FCPA charges with the Justice Department and the SEC for a total of $1 billion (with a B).  Second, Ericsson had an independent compliance monitor appointed...more

Dechert LLP

Nouvelle réforme des lois anti-corruption en France : Les temps changent (de nouveau !)

Dechert LLP on

Il y a presque cinq ans, la France a promulgué sa loi anti-corruption, dite loi Sapin II. Cette loi, considérée comme disruptive à l'époque, a introduit des innovations importantes, y compris la possibilité pour les...more

Dechert LLP

Reforming France’s Anti-Corruption Laws: Times are Changing (Again!)

Dechert LLP on

Almost five years ago, France enacted its anti-corruption legislation, Sapin II. The law was considered ground-breaking at the time and introduced a number of important innovations, including the ability for companies to be...more

Skadden, Arps, Slate, Meagher & Flom LLP

Practical Steps To Address DOJ Changes to Corporate Enforcement Policies

In one of the first substantive speeches on corporate criminal enforcement under the Biden administration, Deputy Attorney General Lisa Monaco announced on October 28, 2021, several immediate changes to Department of Justice...more

Thomas Fox - Compliance Evangelist

Foster Wheeler Settles Corruption Allegations – Bada Bing, Bada Bang and Lessons Learned

I conclude my review of the Amec Foster Wheeler (Foster Wheeler) Foreign Corrupt Practices Act (FCPA) enforcement action. Today, I want to close with the result and some key lessons for the 2021 compliance professional. These...more

WilmerHale

Bribery Act 2010: Ten Years On

WilmerHale on

Ten years have passed since the introduction of the UK’s primary anti-corruption law, the Bribery Act 2010 (“the Act”). This article examines the extent to which the Act has lived up to its billing as the international “gold...more

ArentFox Schiff

Investigations Newsletter: French Concrete Contractor to Pay $3.9 Million FCA Penalty

ArentFox Schiff on

French Concrete Contractor to Pay $3.9 Million FCA Penalty - On February 17, 2021, the Department of Justice (DOJ) announced that a French company, COLAS Djibouti SARL, agreed to pay $3.9 million to resolve allegations...more

Thomas Fox - Compliance Evangelist

Deutsche Bank – FCPA Recidivist: Part 5 – Final Thoughts and Lessons Learned

Last week, according to a Department of Justice (DOJ) Press Release, Deutsche Bank Aktiengesellschaft, “agreed to pay more than $130 million to resolve the government’s investigation into violations of the Foreign Corrupt...more

Thomas Fox - Compliance Evangelist

Deutsche Bank – FCPA Recidivist: Part 3 – Overlooked Red Flags and Internal Control Failures

Last week, according to a Department of Justice (DOJ) Press Release, Deutsche Bank Aktiengesellschaft (DB), “agreed to pay more than $130 million to resolve the government’s investigation into violations of the Foreign...more

The Volkov Law Group

DOJ Hits Beam Suntory with FCPA Settlement for $19.5 Million (Part I of II)

The Volkov Law Group on

Beam Suntory, a global producer and distributor of distilled beverages, settled its FCPA case with DOJ for $19.5 million for bribes paid in India.  The DOJ settlement follows an SEC FCPA settlement for $8 million announced...more

Thomas Fox - Compliance Evangelist

Goldman Sachs: Part 4 – Avoiding a Monitor

We continue our exploration of The Goldman Sachs Group, Inc. (Goldman Sachs) Foreign Corrupt Practices Act (FCPA) settlements and related enforcement action, literally across the globe, from the state of New York to...more

K2 Integrity

Applying Expensive Lessons Learned: The Importance of an Effective Sanctions Compliance Program

K2 Integrity on

For international businesses, the costs of a weak sanctions compliance program can be steep, impacting both a company’s reputation and its bottom line. This year alone, the Treasury Department’s Office of Foreign Assets...more

Hogan Lovells

Not a silver bullet: public procurement lessons from the G4S DPA

Hogan Lovells on

On 17 July 2020, a three-year Deferred Prosecution Agreement (DPA) between the Serious Fraud Office (SFO) and G4S Care & Justice Services (UK) Ltd (G4S) was approved. This DPA is the second arising from fraudulent conduct in...more

Skadden, Arps, Slate, Meagher & Flom LLP

Ericsson Agrees To Pay Over USD $1 Billion To Settle FCPA Charges

On December 6, 2019, Telefonaktiebolaget LM Ericsson (Ericsson or the Company), resolved long-running investigations by the U.S. Department of Justice (DOJ) and the U.S. Securities and Exchange Commission (SEC) into the...more

Thomas Fox - Compliance Evangelist

Billion Dollar Baby: Ericsson FCPA Enforcement Action – Part 5: Lessons Learned for the Compliance Professional

Last week the Justice Department (DOJ) announced a resolution of the long standing Foreign Corrupt Practices Act (FCPA) enforcement action involving Telefonaktiebolaget LM Ericsson (Ericsson), a multinational networking and...more

The Volkov Law Group

Episode 119 -- The Ericsson FCPA Settlement

The Volkov Law Group on

The Sweden-based telecommunications company, Ericsson, agreed to a pay a total of $1 billion (yes, billion with a “B”) for FCPA violations. Ericsson entered into settlement agreements with DOJ and the SEC. Ericsson agreed to...more

The Volkov Law Group

Avanir Pharmaceuticals Pays More than $108 Million to Settle Kickback Violations

The Volkov Law Group on

Just to repeat myself – pharmaceutical and medical device firms face extraordinary risks of enforcement under the False Claims Act.  While everyone likes to write and focus on FCPA or anti-corruption risks for global drug and...more

Dechert LLP

Revised DOJ Policy on Antitrust Compliance Offers New Opportunities for In-House Counsel to Protect Their Companies

Dechert LLP on

Question: Can a company have both an effective antitrust compliance program and an antitrust violation? DOJ before June 11, 2019: Nope. DOJ today: Yes, and your company may even get a deferred prosecution agreement if...more

A&O Shearman

FCPA Digest - Recent Trends and Patterns in the Enforcement of the Foreign Corrupt Practices Act - July 2019

A&O Shearman on

Recent Trends And Patterns In FCPA Enforcement - Although the DOJ and SEC brought a relatively low number of FCPA enforcement actions in the first half of 2019, an unusually large portion of those enforcement actions...more

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