The Legal Tightrope: Surviving Parallel Investigations
Navigating Government Contracts: Diana Shaw on Oversight and Whistleblower Protections
The Presumption of Innocence Podcast: Episode 45 - The Grit, Grace and Gift of Second Chances
The Justice Insiders Podcast - The Ever-Expanding Net: Corporate Compliance in an Era of Increasing Trade Sanctions and Restrictions
False Claims Act Insights - Are All Healthcare “Kickbacks” Subject to FCA Liability?
Episode 333 -- The Boeing Proposed Plea Agreement
DOJ’s New Self-Disclosure Policy and Corporate Whistleblower Awards Pilot Program
False Claims Act Insights - Assessing the Fallout from a Thermonuclear FCA Verdict
FCPA Survival Guide - Step 8 - Investing in Compliance
Exploring the AI and Crypto Intersection
The Justice Insiders Podcast: Jarkesy’s Implications for the Administrative State
The Presumption of Innocence Podcast: Episode 41 - The Dynamics of Decision-Making: Psychology and the Criminal Justice System
INTERPOL and Child Kidnapping Cases. What are INTERPOL’s Abilities and Limitations?
False Claims Act Insights - Eureka! Government Investigators Seek Out Research Misconduct
The Justice Insiders Podcast - AI-Washing: Everything Old Is New Again
The CFPB and State AGs Act Jointly Against Online Educational Company
Will the U.S. Have a GDPR? With Rachael Ormiston of Osano
Episode 328 -- Sanctions Enforcement Risks and Redlines
FCPA Survival Guide: Step 3 - Extensive Remediation
Episode 324 -- Third-Party Risks and Sanctions Compliance
According to the terms of a superseding information made public by the U.S. Attorney’s Office for the Southern District of New York on or about February 13, 2024, Mauricio Gomez Baez (“Baez”)—a former Stericycle executive for...more
As we look back on the anti-corruption enforcement trends we saw in 2023, there were several key developments. The Department of Justice (“DOJ”) brought 11 enforcement actions in 2023. Only six were against companies -...more
Signed into law on December 22, 2023, the Foreign Extortion Prevention Act (FEPA) signals a further focus by the U.S. government on anti-corruption enforcement. Our White Collar, Government & Internal Investigations Team...more
On December 14, 2023, with bipartisan support, Congress passed the Foreign Extortion Prevention Act (“FEPA”), making it a federal crime for any foreign government official to demand, receive, or agree to receive a bribe from...more
The Albemarle FCPA enforcement action was announced at a good time. This year has been a slow year for DOJ’s FCPA enforcement program, although there are several months before the end of the year. The SEC, on the other hand,...more
One of your employees working overseas emails you with great news – they’re about to close a $50 million sale with a new customer. They tell you everything looks great, but there’s just one thing. The local political party...more
The year 2020 witnessed a record level of $2.78 billion in corporate fines and penalties from enforcement of the Foreign Corrupt Practices Act (FCPA) by the U.S. Department of Justice (DOJ) and the U.S. Securities and...more
Last week, I began a multi-part exploration of one world’s largest anti-corruption enforcement actions, the J&F Investimentos SA (J&F) matter. It involved huge fines and penalties in both Brazil and the United States. Of...more
Eddie Van Halen died yesterday. He is the first rocker, more or less, of my generation to die after the age of 60. He was also one of the greatest guitarists ever. Indeed, I would rank him as the best guitarist of his...more
We rarely have seen a single Foreign Corrupt Practices Act (FCPA) enforcement action generate so many individual criminal pleas. The Sargeant Marine Inc. (Sargeant Marine) case is an exception. To date, there have been six...more
On August 14, 2020, the Department of Justice (the “DOJ”) issued its first Foreign Corrupt Practices Act (the “FCPA”) advisory opinion in almost six years....more
The Justice Department continues to pursue criminal cases against Venezuelan officials at Petróleos de Venezuela S.A. (PDVSA) in an attempt to strangle President Nicolas Maduro. DOJ has been pursuing a three-pronged strategy...more
FCPA cases can arise in un usual situations. DOJ has focused two separate prosecutions on bribery and fraud involving adoptions from Uganda and Poland. At the heart, the defendants bribed Ugandan and Polish authorities to...more
On August 14, 2020, the U.S. Department of Justice (“DOJ”) released its first Foreign Corrupt Practices Act (“FCPA”) Opinion (the “August 14 Opinion”) in six years, in response to a request from a multinational company...more
In its continuing aggressive FCPA criminal enforcement program, DOJ announced the indictment of two former Alstom executives and a former Marubeni executive with FCPA violations arising from a bribery scheme in Indonesia....more
Almost every FCPA enforcement action contains important lessons learned in unraveling a bribery scheme. Airbus has three broad divisions: (1) Commercial Division; (2) Defense & Space Division; and (3) Helicopters...more
La Ley de Prácticas Corruptas en el Extranjero (“Foreign Corrupt Practices Act – FCPA”) prohíbe el pago de sobornos a funcionarios extranjeros para ayudar a obtener o retener negocios. Exige que las empresas cuyos valores se...more
The Foreign Corrupt Practices Act (FCPA) prohibits payment of bribes to foreign officials to assist with obtaining or retaining business. It requires companies whose securities are listed in the US to maintain books and...more
On December 6, 2019, the Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) agreed to resolve allegations that multinational telecommunications company Telefonaktiebolaget LM Ericsson (Ericsson or...more
• A payment to a government official can take many forms. • The SEC charges bank for books and records violation even absent a bribery charge. • Industry-wide enforcement is a continuing tactic for U.S. regulators. ...more
Barclays joined the club of global financial institutions settling FCPA violations for hiring of relatives of foreign officials in Asia. Barclays agreed to disgorge $3.8 million and paid prejudgment interest of nearly $1...more
On August 29, 2019, the Securities and Exchange Commission (“Commission” or “SEC”) agreed to resolve an enforcement action against Juniper Networks, Inc. (“Juniper” or the “Company”), a Silicon Valley-based cybersecurity and...more
The Second Circuit’s decision in United States v. Ng Lap Seng is a win for the government, because it reinforces the broad reach and scope of the Justice Department’s enforcement of the FCPA. When adopting and implementing an...more
On August 9, 2019, the US Court of Appeals for the Second Circuit upheld a Chinese real estate developer’s conviction in United States v. Ng Lap Seng. The Court rejected defendant’s attempt to read an “official act”...more
Last week, a grand jury in the Southern District of Florida indicted two former Venezuelan officials, charging them with seven counts of money laundering and one count of money-laundering conspiracy. The charges relate to...more