News & Analysis as of

Deferred Prosecution Agreements Settlement Compliance

The Volkov Law Group

McKinsey Company Pays $122 Million to Resolve FCPA Violations in South Africa (Part I of III)

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On December 5, 2024, DOJ announced a settlement with McKinsey and Company for $122 million for bribes paid to South African government officials to secure valuable consulting contracts....more

The Volkov Law Group

Raytheon’s FCPA and ITAR Case (Part III of IV)

The Volkov Law Group on

Raytheon’s comprehensive settlement included FCPA violations and failures to make required disclosures to the Defense Department concerning fees and commissions. This portion of the settlement was filed in the Eastern...more

ArentFox Schiff

Show Me the Money: Using Compensation Structures to Promote Compliance

ArentFox Schiff on

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

The Volkov Law Group

The Herbalife FCPA Settlement: Board Oversight and Internal Audit Failures

The Volkov Law Group on

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

The Volkov Law Group

Ericsson’s Pervasive Bribery Conduct: The Toxic Mix of Senior Executive Involvement and Third Party Corruption (Part II of II)

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Ericsson’s FCPA settlement is in the books (not the books and records).  But it casts a significant shadow across the FCPA landscape.  A pervasive and systemic culture of bribery is defined to reflect senior executive...more

White & Case LLP

Review of Anti-Money Laundering and Sanctions Policy and Enforcement

White & Case LLP on

TABLE OF CONTENTS: Executive Summary - Developments and Trends in Policy and Enforcement - US Department of the Treasury - The Office of Foreign Assets Control - Treasury's Financial Crimes Enforcement Network -...more

The Volkov Law Group

Société Générale Pays $1.4 Billion for Systemic Sanctions Violations

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Société Générale (“SocGen”) entered into two deferred prosecution agreements (“DPA”) and agreed to pay $1.34 billion in penalties: $717 million to the Justice Department...more

Skadden, Arps, Slate, Meagher & Flom LLP

The Sapin II Act: New Perspectives on Cross-Border Investigations

On November 30, 2017, the Institut des Hautes Etudes sur la Justice (IHEJ) and Skadden hosted a roundtable at the Cercle de l’Union Interalliée in Paris to discuss new perspectives on the Sapin II Act and cross-border...more

A&O Shearman

FCPA Digest - July 2017 - Recent Trends and Patterns in the Enforcement of the Foreign Corrupt Practices Act

A&O Shearman on

Shearman & Sterling’s bi-annual Trends & Patterns in FCPA Enforcement report provides insightful analysis of recent enforcement trends and patterns in the US, the UK and elsewhere, as well as helpful guidance on emerging best...more

The Volkov Law Group

Will the Justice Department Continue to Use DPAs and NPAs?

The Volkov Law Group on

With a new administration at the Department of Justice, practitioners and commentators are looking for signs of change. Given the current politics of the new administration, the Justice Department will undergo changes in...more

The Volkov Law Group

Embraer Finally Lands $205 Million FCPA Settlement (Part I of II)

The Volkov Law Group on

After years of investigation, disclosures, and press reports, the Embraer FCPA case finally came to a close. Hopefully, we will not see more of these long-term, seemingly endless investigations. The Justice Department and the...more

The Volkov Law Group

Fokker: No Judicial Oversight of Deferred Prosecution Agreements

The Volkov Law Group on

The D.C. Circuit dealt a blow last week to judicial attempts to exercise supervision over Justice Department negotiated Deferred Prosecution Agreements. In United States v. Fokker, the Court answered the question in a...more

Bracewell LLP

VimpelCom's Global FCPA Settlement - A Multinational Resolution

Bracewell LLP on

The U.S. Department of Justice (DOJ), the U.S. Securities and Exchange Commission (SEC) and the Public Prosecution Service of the Netherlands (OM) announced a coordinated criminal and civil Foreign Corrupt Practices Act...more

BakerHostetler

Foreign Corrupt Practices Act 2015 Update

BakerHostetler on

Despite a decline in enforcement actions by the Securities Exchange Commission (“SEC”) and the Department of Justice (“DOJ”), the first half of 2015 has continued to highlight the relevance and ever-evolving effects of the...more

Thomas Fox - Compliance Evangelist

Total Switches To Settle Rather Than Fight

For anyone who grew up in the 1960s, I am sure that you remember the touchstone slogan for Tareyton cigarettes, “I’d rather fight than switch”. ...more

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