News & Analysis as of

Enforcement Actions Securities and Exchange Commission (SEC) Third-Party Risk

Ankura

The Extended Network: Managing Third Parties' Bribery Risks

Ankura on

Approximately 90% of U.S. Foreign Corrupt Practices Act (FCPA) enforcement cases from its inception in 1978 have involved third-party intermediaries engaging in bribery schemes. The reduced level of control or oversight...more

Baker Donelson

[Webinar] New Privacy and Cybersecurity Regulations: What Financial Institutions Need to Know to Stay Compliant - June 13th, 10:00...

Baker Donelson on

The financial services industry has seen a litany of new data privacy and cybersecurity challenges through the first half of 2024. Financial institutions are facing unprecedented compliance hurdles resulting from the...more

Jenner & Block

[Ongoing Program] CLE Relay – Session 3 – Hot Topics in Fintech and Crypto - June 7th, 10:00 am - 11:00 am PDT

Jenner & Block on

This session will provide a survey of key issues and trends impacting the fintech and digital assets community as well as the future opportunities and challenges presented for these financial products and services. It will...more

American Conference Institute (ACI)

[Event] 17th Forum on the Foreign Corrupt Practices Act - January 24th - 25th, Houston, TX

As the most anticipated gathering for the community in Texas and the region, don’t miss out on re-connecting with your peers and more! With the continued focus on FCPA compliance and the anticipated rise in enforcement,...more

American Conference Institute (ACI)

[Event] 40th International Conference on the FCPA - November 28th - 30th, National Harbor, MD

Hosted by American Conference Institute, the 40th International Conference on the FCPA returns for another exciting year with curated programming that shines a global spotlight on anti-corruption compliance challenges,...more

The Volkov Law Group

Oracle’s FCPA Violations: A Lesson in Managing Third-Party Distributor Risks (Part II of II)

The Volkov Law Group on

Oracle’s SEC settlement for $23 million underscores the power of the FCPA provisions mandating effective internal controls and accurate books and records.  As everyone knows, these provisions can be applied to a wide-range of...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

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

ArentFox Schiff

Managing Third-Party Risk: Recent FCPA Action Reflects Government’s Continued Focus on Intermediaries

ArentFox Schiff on

Amec Foster Wheeler Energy Limited (the Company), a subsidiary of John Wood Group plc (Wood), a United Kingdom-based global engineering company, agreed to pay more than $41 million in penalties and disgorgement for alleged...more

American Conference Institute (ACI)

[Virtual Event] 37th International Conference on the FCPA - December 2nd - 3rd, 9:00 am - 4:30 pm EST

The Annual Gathering for the Global Anti-Corruption Community - Exclusive Interview with President of Microsoft at FCPA DC - The world has reached an inflection point in which digital technology is being used as both a...more

The Volkov Law Group

Letting Third Parties Do the Dirty Work

The Volkov Law Group on

We all know it when we see it – a recurring fact pattern in which a company enlists a corrupt third party intermediary for one purpose (and one purpose only) – to pay a bribe.  Let me give you a few examples....more

The Volkov Law Group

2019 OFAC Sanctions Enforcement Review (Part I of II)

The Volkov Law Group on

While DOJ had its biggest year in FCPA enforcement, OFAC quietly had a record year in enforcement.  OFAC collected approximately $1.28 billion (yes, with a B) in 26 separate enforcement actions.  That is quite an increase...more

Foodman CPAs & Advisors

Instituciones Financieras y el FCPA

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

Foodman CPAs & Advisors

Financial Institutions and the FCPA

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

Thomas Fox - Compliance Evangelist

Billion Dollar Baby: Ericsson FCPA Enforcement Action – Part 5: Lessons Learned for the Compliance Professional

Last week the Justice Department (DOJ) announced a resolution of the long standing Foreign Corrupt Practices Act (FCPA) enforcement action involving Telefonaktiebolaget LM Ericsson (Ericsson), a multinational networking and...more

Thomas Fox - Compliance Evangelist

Billion Dollar Baby: Ericsson FCPA Enforcement Action - Part 4: The Double Whammy in Penalties

Last week the Justice Department (DOJ) announced a resolution of the long standing Foreign Corrupt Practices Act (FCPA) enforcement action involving Telefonaktiebolaget LM Ericsson (Ericsson), a multinational networking and...more

Thomas Fox - Compliance Evangelist

Billion Dollar Baby: Ericsson FCPA Enforcement Action – Part 3: Internal Control Failures

Last week the Justice Department (DOJ) announced a resolution of the long standing Foreign Corrupt Practices Act (FCPA) enforcement action involving Telefonaktiebolaget LM Ericsson (Ericsson), a multinational networking and...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)

The Volkov Law Group on

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

The Volkov Law Group

Lessons Learned from the Walmart FCPA Enforcement Action (Part III of III)

The Volkov Law Group on

This is a tough posting – frankly, there are so many lessons learned from the Walmart case that they could fill a book, or an e-book at least.  I will focus on some of the big issues....more

Thomas Fox - Compliance Evangelist

Fresenius FCPA Enforcement Action: Part VI – FCPA Enforcement Going Forward

We are at the end of my exploration of the long-awaited Fresenius Medical Care AG & Co. KGaA (FMC) Foreign Corrupt Practices Act (FCPA) enforcement action. ...more

Thomas Fox - Compliance Evangelist

Fresenius FCPA Enforcement Action: Part III – The NPA, Fines and Monitor

I continue my multipart (not quite sure how long it will go) exploration of last week’s announcement of the Fresenius Medical Care AG & Co. KGaA (FMC) Foreign Corrupt Practices Act (FCPA) enforcement action. It involved...more

Thomas Fox - Compliance Evangelist

Fresenius FCPA Enforcement Action: Part II –  The Bribery Schemes

Last week, the long-awaited Fresenius Medical Care AG & Co. KGaA (FMC) Foreign Corrupt Practices Act (FCPA) enforcement action was announced. It involved massive multi-year and multi bribery schemes by the company in multiple...more

The Volkov Law Group

Lessons Learned from Fresenius Medical FCPA Settlement (Part III of III)

The Volkov Law Group on

Fresenius Medical’s FCPA settlement for $231 million demonstrates again the continuing vitality surrounding the FCPA Corporate Enforcement Policy – which provides a carefully constructed framework for encouraging voluntary...more

The Volkov Law Group

First FCPA Action of 2018: Elbit Imaging

The Volkov Law Group on

No one needs to be reminded about the importance of anti-corruption compliance. For global companies, anti-corruption risks are amongst the top 3 risks identified by corporate leaders....more

The Volkov Law Group

FCPA Recidivists: Zimmer Biomet (Part I of II)

The Volkov Law Group on

The drug and medical device industries have been taking it on the FCPA chin for years. The risk factors in the international marketplace are significant – healthcare professionals are normally government employees; government...more

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