News & Analysis as of

Enforcement The Foreign Corrupt Practices Act

Deputy Attorney General Rod Rosenstein Announces Revised FCPA Corporate Enforcement Policy

by Shearman & Sterling LLP on

On November 29, 2017, Deputy Attorney General Rod Rosenstein delivered remarks at the 34th International Conference on the Foreign Corrupt Practices Act (“FCPA”), in which he announced a revised FCPA Corporate Enforcement...more

DOJ Expands and Codifies Policy Incentivizing Corporations to Voluntarily Self-Disclose FCPA Violations

by Latham & Watkins LLP on

The revised FCPA Corporate Enforcement Policy signals DOJ’s emphasis on corporate voluntary self-disclosure, rewarding cooperating companies with a presumption in favor of declination and reductions in penalties. Please...more

U.S. Department of Justice Adopts New FCPA Corporate Enforcement Policy to Enhance FCPA Pilot Program

When a company learns that an employee or third-party business partner may have bribed a foreign official, it is never an easy question as to whether the company should turn itself in to the U.S. government. On November 29,...more

DOJ Announces New FCPA Corporate Enforcement Policy

by WilmerHale on

On November 29, 2017, “[d]ue to the unique issues presented in FCPA matters,” Deputy Attorney General Rod Rosenstein announced a new FCPA corporate enforcement policy published in a revision to the United States Attorneys'...more

For US Employers Operating in Mexico, Anti-Corruption Compliance Now is a Multi-Jurisdictional Obligation

by Fisher Phillips on

For several decades, US employers operating in Mexico (or anywhere else around the globe, for that matter) have been subject to – and, therefore, should be aware of – the tenets of the federal Foreign Corrupt Practices Act...more

Conducting investigations in China: four common pitfalls

by DLA Piper on

Conducting an investigation in a foreign country can be challenging, given the unfamiliarity with local laws, dynamic market conditions, the unpredictability of local enforcement actions, and language barriers. Deep local...more

FCPA Compliance Report-Episode 333, Professor Samuel Buell

by Thomas Fox on

Today I am joined again by Professor Samuel Buell, from Duke University School of Law to discuss a recent paper he co-authored with Rachel Brewster entitled, “The Market for Global AntiCorruption Enforcement“. In the paper...more

Everything Compliance-Episode 11, the first 100 Days of the Trump Administration, Part II

by Thomas Fox on

In this second of a two-part series, we conclude the panel’s discussion of the first 100 days of the Trump administration as it relates to compliance. This episode concludes with the panelists’ rants. 1. Matt Kelly opens...more

SEC Speaks 2017

by Morgan Lewis on

Commission staff highlight key developments and successes in the SEC enforcement program. As they do every year, senior officials from the US Securities and Exchange Commission (SEC or the Commission), including current...more

Viewpoints - Issue 24 - A Dialogue with Andrew Ceresney

by King & Spalding on

On October 7, 2015, members of the Lead Director Network (LDN) were joined by chief legal officer and general counsel (GC) guests in Washington, DC, for a discussion with Andrew Ceresney, director of the Division of...more

DOJ Quietly Revises FCPA Resource Guide

by Morgan Lewis on

Revisions bring DOJ and SEC guidance in line with FCPA statutory language. In June, the US Department of Justice (DOJ) and Securities and Exchange Commission (SEC) quietly revised its manual, A Resource Guide to the U.S....more

Canada’s New Extractive Sector Transparency Measures Act and its Implications for Companies Subject to the U.S. Foreign Corrupt...

by Morrison & Foerster LLP on

On June 1, 2015, Canada’s Extractive Sector Transparency Measures Act (“ESTMA” or “the Act”) came into force. Approved in December 2014, but not in force until this month, the Act requires companies in the extractive sector...more

Corporate Investigations & White Collar Defense - June 2015

The Unfolding FIFA Scandal: Will the DOJ Show the Banks a Red Card? - Why it matters: The worldwide soccer community has for years decried the brazen corruption that permeated FIFA, international soccer’s governing...more

Top Ten International Anti-Corruption Developments for May 2015

by Morrison & Foerster LLP on

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 in the past month with links to primary...more

Two Sides of A Global Corruption Investigation at Anti-Corruption Oslo

This is the second part of my interview with Robert (“Bob”) Appleton, which is timely given our question and answer session at the upcoming Anti-Corruption Conference, Oslo, where we will engage in an interview titled...more

Why Should Americans Care About the FIFA Indictments? Part I – Only the US Government Could Do It

by Thomas Fox on

A colleague recently posed that question to me. I thought it was an interesting one and although at first blush the response to me might appear self-evident, the fact that it was posed means that my view may not be universal....more

Bribery & Corruption in the Military. A Front-Line View (Part II)

In the second part of my interview on "The Heat" via CCTV, I discuss the temptations that front-line personnel face when dealing with overseas militaries, particularly, procurement personnel. I share how the touch points...more

Robert Appleton: It’s FCPA Compliance or Vegas

Today is the first of a two part interview with Robert “Bob” Appleton and is an edited version of the entire interview which will be available for download when part II is published next week....more

Texas Supreme Court: Companies Shielded from Defamation Claims for Statements in Internal Investigation Reports

Last week, the Texas Supreme Court joined the majority of jurisdictions in holding that a company enjoys an absolute privilege when providing the Department of Justice (DOJ) with an internal investigation report containing...more

DOJ: Companies Need Not Expend Exorbitant Fees to Get Full Cooperation Credit

by Morgan Lewis on

During an FCPA panel event, the Chief of the US Department of Justice’s Fraud Section advised companies to conduct “targeted” FCPA investigations, dismissing the suggestion that companies must spend hundreds of millions of...more

FCPA Compliance and Ethics Report-Episode 145-SEC Enforcement of the FCPA, Part II

by Thomas Fox on

In this episode which is Part II of my look at SEC enforcement of the FCPA, I consider whether profit disgorgement is available to the SEC in a strict liability enforcement action of violation of internal controls. ...more

The Companion and SEC Enforcement of the FCPA – Part II

by Thomas Fox on

I will use Agatha Christie’s short story The Companion as the introduction to today’s blog post. This story, related by one of the Tuesday story-telling group of detective aficionados, Dr. Lloyd, and is about two people who...more

Miss Marple Short Stories and SEC Enforcement of the FCPA, Part I

by Thomas Fox on

I am a huge Agatha Christie fan. I have read most of the Poriot novels and many of the Jane Marple novels as well. However, I was not aware of Christie’s work in the short story format until I recently read a volume entitled...more

Is Strict Liability Coming to FCPA Enforcement?

by Thomas Fox on

I think that a strict liability standard is coming to Foreign Corrupt Practices Act (FCPA) enforcement. A number of factors have caused me to come to this conclusion. While there may well be wide disagreement as to whether...more

This Week In Securities Litigation

by Dorsey & Whitney LLP on

Four SEC Commissioners addressed the annual SEC Speaks Conference, reviewing recent agency initiatives and tracing potential paths for the future. The SEC also brought another FCPA action, a misappropriation case and an...more

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