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Due Diligence Compliance White Collar Crimes

Benesch

White Collar Quarterly Report - August 2024

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In 2023, the number of federal corporate prosecutions remained far below the 25-year average after two consecutive years of increases. ..The DOJ’s Fraud Section secured just $690 million in penalties across eight...more

The Volkov Law Group

The Magnificent Seven: Important Ways to Mitigate Your Third-Party Sanctions Risks (Part IV of IV)

The Volkov Law Group on

It may seem like a Herculean task — but it can be done.  I regularly opine that mitigating sanctions risks for your third-party population is an easier task than doing so for your anti-corruption risks.  One big reason —...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

DOJ Official Cites Old West ‘WANTED’ Posters in Announcement of New Whistleblower Monetary Awards Program

On March 7, 2024, Deputy Attorney General Lisa Monaco said that the U.S. Department of Justice (DOJ) will test out a program to pay whistleblowers if they provide information on serious financial crimes and foreign and...more

American Conference Institute (ACI)

Sanctions Compliance Measures to Mitigate Russia Trade Sanctions Evasion Tactics

The various and elusive tactics used by Russia to evade global sanctions and export controls have grown increasingly sophisticated over the last several months, putting the onus on multinational entities to become equally...more

Mintz

EnforceMintz — DOJ’s Efforts in 2023 to Incentivize Voluntary Self-Disclosure

Mintz on

2023 was a very active one for Department of Justice (DOJ or the “Department”) guidance, and that guidance had one clear theme: DOJ wants companies to voluntarily self-disclose their misconduct. To incentivize...more

A&O Shearman

Top challenges for white collar crime and investigations lawyers in 2024

A&O Shearman on

We asked our global white collar crime team for their views on the key challenges in 2024 for in‑house investigations teams and white collar crime lawyers, and how to manage the associated risks. Here is what they said. ...more

DarrowEverett LLP

How DOJ's Safe Harbor Policy Rewards Honesty Within M&A Deals

DarrowEverett LLP on

Be you a merger and acquisition attorney, corporate compliance officer, or counsel to an acquiring entity or target entity, you should review the Department of Justice’s new Merger and Acquisition Safe Harbor Policy...more

K&L Gates LLP

Why Corporates Are Now More Likely to Face Criminal Prosecution for the Actions of Their Employees

K&L Gates LLP on

Significant Expansion to Corporate Criminal Liability Becomes Law in the United Kingdom - On 26 October 2023, the Economic Crime and Corporate Transparency Act (the Act) became law. Under the Act, corporations will become...more

Troutman Pepper

The Stick and the Carrot: DOJ Continues to Eye Corporate Crimes, While Encouraging Prompt Self-Disclosures of Misconduct...

Troutman Pepper on

On October 4, Deputy Attorney General (DAG) Lisa Monaco announced the Department of Justice’s (DOJ) new Safe Harbor Policy for voluntary self-disclosures made in connection with mergers and acquisitions (M&A). This policy is...more

Robinson & Cole LLP

DOJ Announces Extension of Voluntary Self-Disclosure Guidance for Misconduct Discovered Through M&A Due Diligence

Robinson & Cole LLP on

On October 4, 2023, the U.S. Department of Justice (DOJ) announced a uniform approach for the resolution of voluntary self-disclosure (VSD) of misconduct discovered during M&A due diligence. The Mergers & Acquisitions Safe...more

The Volkov Law Group

Flutter Entertainment Settles SEC FCPA Case for $4 Million for Improper Payments to Russian Consultants

The Volkov Law Group on

Flutter Entertainment, the previous owner of PokerStars, agreed to pay the Securities and Exchange Commission $4 million for improper payments to Russian-based consultants, stemming from conduct committed by The Stars Group,...more

McDermott Will & Emery

International Legal Highlights | June 2022

EUROPEAN COMMISSION ADOPTED A PROPOSAL DIRECTIVE ON CORPORATE SUSTAINABILITY DUE DILIGENCE - On 23 February 2022, the European Commission (EC) adopted a proposal for a directive on corporate sustainability due diligence...more

The Volkov Law Group

WPP SEC FCPA Enforcement Action: Lessons Learned (Part III of III)

The Volkov Law Group on

The SEC’s FCPA enforcement action against WPP presents a number of important lessons learned, ranging from third-party risk management, properly responding to employee complaints and red flags, and failure to integrate...more

The Volkov Law Group

Lessons Learned: Foster Wheeler FCPA Settlement Underscores Danger of Third-Party Risks (Part III of III)

The Volkov Law Group on

We all know and hear about third-party risks – over and over again. Despite this recurring theme, organizations continue to pay the price for failing to address third-party issues.  It does not take a rocket scientist to...more

The Volkov Law Group

OFAC Screening and Internal Controls

The Volkov Law Group on

Companies have had over one year to review and implement a sanctions compliance guidance program.  This last year, however, has been difficult (to say the least) given the COVID-19 pandemic....more

The Volkov Law Group

Lessons Learned from the Goldman Sachs FCPA Enforcement Settlement (Part III of III)

The Volkov Law Group on

Goldman Sachs has a new leadership role – unfortunately, it is for corruption.  It would be a serious mistake to characterize or describe the Goldman corruption scheme as the result of a few, bad actors.  Instead, Goldman...more

Vinson & Elkins LLP

[Webinar] Corruption in the Time of COVID-19 - September 16th, 8:00 am - 9:00 am CT

Vinson & Elkins LLP on

While GDP and worldwide economies shrink under the continuing impact of COVID-19, government budgets have expanded to support healthcare responses to the pandemic and social-welfare in response to growing unemployment and...more

Thomas Fox - Compliance Evangelist

Compliance in the Hundred Acre Wood: Winnie the Pooh as CECO (Think, Think, Think)

This blog post series has been one of the most popular of any series I have ever run. Compliance loves Pooh. As well they should as today, I want to conclude my series by looking at Pooh through the lens of the Chief Ethics...more

The Volkov Law Group

Rebalancing Third-Party Risk Strategies

The Volkov Law Group on

As companies move forward on third-party risk management programs, and as automated third-party risk solutions are being implemented, compliance professionals have to re-examine and re-balance the allocation of resources and...more

Thomas Fox - Compliance Evangelist

New Year, New Compliance Game Plan

With a new year, many folks have been promoted to the CCO chair. What should be your plan starting the new year and a new job. The answer is found in the  eBook Compliance Program Game Plan by myself and Jonathan Marks. ...more

Thomas Fox - Compliance Evangelist

What is the Intersection of Star Wars and Compliance? Find Out This Week

On Monday, December 16, we begin with Episode IV-A New Hope and management of risk. We use Grand Moff Tarkin’s incorrect assessment that the risk presented by the Rebellion’s final attack on the Death Star was non-lethal. I...more

Jones Day

Anti-Corruption Regulation Survey of 42 Countries 2019

Jones Day on

Welcome to the 2019 edition of the Jones Day Anti-Corruption Regulation Survey of Select Countries. Since the 2017–2018 edition of this Survey, there has continued to be an increasing awareness among multinational companies...more

Thomas Fox - Compliance Evangelist

The OFAC Compliance Framework: Element 2 – Risk Assessment

I am in a multipart series on the Framework for OFAC Compliance Commitments (Framework). Every compliance professional of any stripe needs to read, understand and implement some of the key concepts of the Framework into your...more

The Volkov Law Group

Five Lessons for Third-Party Distributor Risk Management from Microsoft FCPA Settlement (Part III of III)

The Volkov Law Group on

The Microsoft FCPA settlement, while not significant in the total penalty of approximately $25 million, provides some important instructions concerning distributor and re-seller risks and mitigation strategies.  ...more

Thomas Fox - Compliance Evangelist

Just Who Are You Doing Business With In China?

How important is due diligence on those with whom you are doing business? Why does it matter if a company is owned or controlled by a foreign government or a political party member of a foreign government? ...more

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