News & Analysis as of

Due Diligence Foreign Corrupt Practices Act (FCPA) Corruption

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

NAVEX

What a New SEC Enforcement Sweep Is Really Telling Us

NAVEX on

Attention all compliance officers at large technology companies – have you checked your mail lately? Because you might find a letter from the Securities and Exchange Commission with FCPA risk written all over it....more

Society of Corporate Compliance and Ethics...

Third-party due diligence: Are supplier questionnaire(s) the answer?

Numerous laws (U.K. Bribery Act guidance document, German Supply Chain Act, Foreign Corrupt Practices Act resource guide, OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and...more

Thomas Fox - Compliance Evangelist

Levels of Due Diligence

Due diligence is generally recognized in three levels: Level I, Level II and Level III. Each level is appropriate for a different level of corruption risk. The key is to develop a mechanism to determine the appropriate level...more

American Conference Institute (ACI)

[Event] 9th Anti-Corruption and Corporate Social Responsibility Conference - October 9th - 10th, Puteaux, France

Hosted by C5 Group, the 9th Anti-Corruption Conference in Paris returns for another exciting year with curated programming that will shed light on important issues at the forefront....more

American Conference Institute (ACI)

[Event] 13th West Coast Forum on FCPA Enforcement and Compliance - June 14th - 15th, San Francisco, CA

Hosted by American Conference Institute, the 13th West Coast Forum on FCPA Enforcement and Compliance returns for another exciting year, providing the opportunity to connect with decision-makers from your industry, gather...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

Oberheiden P.C.

Internal Audit for FCPA Compliance: A Detailed Guide

Oberheiden P.C. on

The Foreign Corrupt Practices Act (FCPA) (15 U.S.C. § 78dd-1 et seq.) is a federal anti-bribery law that makes it unlawful for certain people to pay foreign government officials in order to conduct business abroad. While it...more

The Volkov Law Group

Lessons Learned from the KT Corp. SEC FCPA Settlement (Part III of III)

The Volkov Law Group on

Even though the size of the KT Corp. SEC enforcement action is relatively small, the underlying misconduct provides a number of important lessons learned. ...more

American Conference Institute (ACI)

[Event] Mexico Summit on Anti-Corruption & Compliance Programs - March 22nd - 23rd, Mexico City, Mexico

Join the Go-To Event of the Year for Mexico’s Anti-Corruption Community. The annual ACI’s Anti-Corruption Summit in Mexico is back to Mexico City on March 22-23, 2022! This is the most important anti-corruption compliance...more

The Volkov Law Group

Credit Suisse’s Global Bribery and Fraud Scheme (Part II of II)

The Volkov Law Group on

The Credit Suisse case highlights the significant impact that global corruption and fraud can have on developing economies.  Mozambique’s economy suffered serious harm from the scheme, which started to unravel when the IMF...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

Pillsbury Winthrop Shaw Pittman LLP

DOJ Continues Targeting of Corruption through AML Laws and Alternate Statutes – Lessons for Compliance and Due Diligence

As the Biden Administration commits to crack down on corruption, recent enforcement actions show the DOJ continues a longstanding trend of relying on AML laws and other alternate statutes to prosecute corruption cases, with...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

American Conference Institute (ACI)

[Event] Anti-Corruption London - November 2nd - 3rd, London, United Kingdom

C5's 15th International Conference on Anti-Corruption London will take place November 2 – 3, 2021 in Millennium Hotel London Knightsbridge, London. Join your peers for the IN-PERSON reunion of the legal and compliance...more

The Volkov Law Group

Foster Wheeler FCPA Action: Dancing with the Devil – Risky Third Parties (Part II of III)

The Volkov Law Group on

FCPA settlement actions often underscore specific compliance risks for legal and compliance professionals. If there ever was a case where third-party risks were bungled, and even intentionally embraced, the Foster Wheeler...more

Cadwalader, Wickersham & Taft LLP

COVID-19 Update: Are You For Real? Due Diligence in the Age of Coronavirus

In the context of COVID-19, there are significant challenges involved in conducting due diligence: hard-copy documents are inaccessible, in-person meetings have moved online, and on-site visits may be impossible....more

Foley & Lardner LLP

Recent Government Announcements Confirm Importance of International Regulatory Compliance for Automotive Companies

Foley & Lardner LLP on

Over the last three years, the current administration has imposed the largest export controls penalty, the second-largest economic sanctions penalty, and four of the ten largest anti-bribery penalties of all time, signaling...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

White & Case LLP

Does your compliance program address UK exposure?

White & Case LLP on

Tech companies of U.S. origin tend to have compliance programs focused on U.S. laws, including the Foreign Corrupt Practices Act (the "FCPA") and relevant tax and labor laws. The UK has enacted laws covering bribery and...more

The Volkov Law Group

Vantage Drilling Forks Over $5 Million for SEC FCPA Settlement

The Volkov Law Group on

The SEC announced last week a $5 million FCPA settlement with Vantage Drilling International (“Vantage”), a Texas-based offshore drilling company. ...more

Thomas Fox - Compliance Evangelist

Goldman Sachs, 1MDB and Initial Lessons Learned

This week I have been considering the new developments in the long-running 1Malaysia Development Berhad (1MDB) scandal. These developments include a guilty plea by a former Goldman Sachs Group Inc. (Goldman Sachs) banker in...more

Orrick, Herrington & Sutcliffe LLP

DOJ Encourages Self-Disclosure Of FCPA Violations Discovered Through M&A Activity

Deputy Assistant Attorney General Matthew Miner, head of the DOJ’s Fraud Section, recently discussed the DOJ’s efforts to address corruption discovered during mergers and acquisitions....more

Alston & Bird

DOJ Extends FCPA Corporate Enforcement Policy to Mergers and Acquisitions

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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

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