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Due Diligence Department of Justice (DOJ) Corporate Counsel

ArentFox Schiff

How to Avoid an Independent Compliance Monitor: Lessons From the SAP Settlement

ArentFox Schiff on

This week, SAP SE (SAP), the German-based software company, agreed to pay over $200 million to resolve investigations by the US Department of Justice (DOJ) and US Securities and Exchange Commission (SEC) into violations of...more

ArentFox Schiff

What Does the New FEPA Legislation Mean for FCPA and Anti-Corruption Compliance Programs?

ArentFox Schiff on

On December 21 President Biden signed the Foreign Extortion Prevention Act (FEPA) as part of the Fiscal Year 2024 National Defense Authorization Act. The legislation addresses a perceived gap in the Foreign Corrupt Practices...more

White & Case LLP

Corporate Liability for Terrorist Financing

White & Case LLP on

Terrorist financing comes at a price – and in the case of a global building supplies manufacturer that has pleaded guilty in a US court to making payments to terrorist organisations, that price is USD 778 million in fines and...more

Fox Rothschild LLP

Small Business Compliance Due Diligence Leads to Reduced FCA Penalty

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Earlier this month, the Department of Justice (DOJ) announced a $5.2 million civil settlement agreement to resolve small business set-aside fraud allegations against an aerospace contractor. While the $5+ million...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

Health Care Compliance Association (HCCA)

[Event] Regional Healthcare Compliance Conference - January 28th, Orlando, FL

Looking for compliance training and networking in your area? HCCA’s Regional Healthcare Compliance Conferences offer practitioners convenient, local compliance training, including updates on the latest news in regulatory...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments For March 2021

In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international anti-corruption developments from the past month, with links to primary...more

Perkins Coie

Rare DOJ Opinion Offers Anti-Bribery Lessons for Transactions Involving Foreign Government-Owned Assets

Perkins Coie on

The U.S. Department of Justice (DOJ) has issued an opinion letter (catalogued as FCPA Opinion No. 20-01) stating that it does not intend to take enforcement action under the Foreign Corrupt Practices Act (FCPA) against a...more

Oberheiden P.C.

A CEO's Guide to FCPA Compliance

Oberheiden P.C. on

- A tone-at-the-top business culture with CEO leadership is a critical component of effective anti-corruption and anti-bribery policy implementation. - CEO leadership helps set an example for lower management and company...more

K&L Gates LLP

DOJ Emphasizes Data-Driven Approach to Monitoring and Importance of Culture in Latest Adjustments to Corporate Compliance Program...

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I. INTRODUCTION - On 1 June 2020, the Criminal Division of the U.S. Department of Justice (DOJ) updated a critical guidance document, the “Evaluation of Corporate Compliance Programs” memorandum (“Guidance”), providing...more

BakerHostetler

DOJ Makes Important Changes to Its Guidance on Evaluating Compliance Programs

BakerHostetler on

On June 1, 2020, the Criminal Division (the “Criminal Division”) of the Department of Justice (the “DOJ” or “Department”) issued revised guidance (the “June 2020 Guidance”) about how it will evaluate corporate compliance...more

Alston & Bird

DOJ Issues Third Iteration of Its Corporate Compliance Guidance

Alston & Bird on

The Department of Justice revised its corporate compliance guidance for the third time in three years. Our White Collar, Government & Internal Investigations Team breaks down the key updates and offers insight to the DOJ’s...more

Morrison & Foerster LLP

DOJ Provides New Guidance On Corporate Compliance Programs

On June 1, 2020, the U.S. Department of Justice (“DOJ”) published a revised version of its guidance on the “Evaluation of Corporate Compliance Programs” (the “June 2020 Guidance”). Like its predecessors in February 2017 and...more

Morgan Lewis

UK Serious Fraud Office Emphasizes Importance of Compliance Programs

Morgan Lewis on

In a recent update to its internal guidance, the UK Serious Fraud Office provides insight into the general approach its investigators may take for evaluating organizations’ compliance programs—an approach similar to that of...more

King & Spalding

Corporate Compliance Programs: DOJ Issues Updated Guidance: Ten Takeaways for In-House Legal and Compliance Leaders

King & Spalding on

On April 30, 2019, Assistant Attorney General Brian Benczkowski unveiled an update to the Department of Justice’s Evaluation of Corporate Compliance Programs during a speech in Dallas, Texas. In issuing the new document (the...more

Alston & Bird

DOJ Extends FCPA Corporate Enforcement Policy to Mergers and Acquisitions

Alston & Bird on

Our Government & Internal Investigations Team discusses the implications of the Justice Department’s decision to extend its FCPA Corporate Enforcement Policy to M&A transactions and how acquiring and successor corporations...more

Jones Day

Anti-Corruption Regulation Survey of 41 Countries 2017–2018

Jones Day on

Welcome to the 2017-2018 edition of the Jones Day Anti-Corruption Regulation Survey. In 2017 and 2018 to date, there has continued to be an increasing awareness among multinational companies of the significance of...more

Foley & Lardner LLP

U.S. Customs and the New Trump Administration: Your Top Ten Questions Answered

Foley & Lardner LLP on

During the campaign, U.S. Customs & Border Protection (CBP) was mostly mentioned by President Trump in the context of illegal immigration. Controlling the flow of people, however, is only one of the jobs of CBP, which is part...more

The Volkov Law Group

C-Suite Misconduct Results in Sociedad Quimica Y Minera FCPA Resolution with DOJ and SEC

The Volkov Law Group on

In an unusual FCPA enforcement action, the Justice Department and the SEC resolved FCPA violations against Sociedad Quimica y Minera, a Chilean chemical and mining company, for a total of $30.5 million, for paying...more

The Volkov Law Group

Trends from 2016 Record FCPA Enforcement Year (Part II of III)

The Volkov Law Group on

No matter how you cut it – this was a big year in FCPA enforcement. Not just because of the large enforcement actions but the scope and depth of enforcement, remediation and compliance program demands....more

The Volkov Law Group

Lessons Learned From FCPA Enforcement Against JP Morgan for Sons and Daughters Referral Program

The Volkov Law Group on

Last week, the Justice Department and the SEC finally brought to a close the Sons and Daughters or Princelings investigation. Pending investigations against four other companies still remain to be resolved....more

NAVEX

Landmark SEC Decision Cites Compliance, Diligence in Decision Not to Prosecute FCPA Violations

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In a remarkable affirmation of the value of robust compliance and due-diligence programs, the Securities and Exchange Commission last month announced that it would not prosecute a U.S. company for potential violations of the...more

The Volkov Law Group

Och-Ziff Failures in Due Diligence and Transaction Compliance (Part II)

The Volkov Law Group on

The Och-Ziff enforcement action is replete with examples of failures in due diligence and transaction monitoring compliance. Och-Ziff’s bribery schemes were elaborate and intricate and involved complex transactions,...more

The Volkov Law Group

5 Key Takeaways from AB InBev SEC FCPA Settlement

The Volkov Law Group on

The Justice Department and the SEC have been busy over the last 2 weeks in the FCPA arena. For those who have raised doubts about DOJ and the SEC’s continuing commitment to FCPA enforcement, you should forever hold your...more

Thomas Fox - Compliance Evangelist

The Ping FCPA Enforcement Action: Lessons for the Compliance Practitioner

The Securities and Exchange Commission (SEC) settled a Foreign Corrupt Practices Act (FCPA) enforcement action against an individual earlier this month when it announced the resolution of a matter involving Jun Ping Zhang,...more

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