News & Analysis as of

Extortion Compliance

Eversheds Sutherland (US) LLP

More carrots, more sticks - DOJ announces agency-wide whistleblower pilot program

The Department of Justice has announced yet another pilot program, adding to their “mix of carrots and sticks” designed “to promote responsible corporate citizenship.” The new whistleblower pilot program, which is still under...more

Latham & Watkins LLP

DOJ Announces New Whistleblower Program

Latham & Watkins LLP on

DOJ unveils a new whistleblower incentive program to complement the Department’s continued efforts to encourage self-reporting of criminal violations. On Thursday, March 7, 2024, US Deputy Attorney General Lisa Monaco...more

Lowenstein Sandler LLP

Anti-Bribery Expansion: The Foreign Extortion Prevention Act

Lowenstein Sandler LLP on

On December 22, 2023, President Biden signed into law the 2024 National Defense Authorization Act. This bipartisan legislation included the Foreign Extortion Prevention Act (FEPA), which enables criminal prosecution of...more

BakerHostetler

Congress Expands DOJ’s Power to Prosecute Corruption with the Foreign Extortion Prevention Act

BakerHostetler on

Adding to federal prosecutors’ tool kit in fighting global corruption, on December 14, 2023, Congress passed with bipartisan support, the Foreign Extortion Prevention Act (FEPA). As part of the National Defense Authorization...more

Foley Hoag LLP

U.S. Congress Passes Foreign Extortion Prevention Act Imposing Liability on Foreign Officials Who Receive or Demand Bribes From...

Foley Hoag LLP on

The U.S. Congress has passed the Foreign Extortion Prevention Act (“FEPA”), as part of the National Defense Authorization Act for Fiscal Year 2024 (“NDAA”). On December 14, 2023, the measure was sent to President Biden, who...more

Thomas Fox - Compliance Evangelist

Extortion Payments, Opinion Release 22-01 and the FCPA

Last week I wrote about the first Opinion Release for 2022, appropriately named Opinion Release 22-01. Several persons emailed me about my analysis and discussion, concluding with the point that there was no need for an...more

Thomas Fox - Compliance Evangelist

Creative Lawyerin’ and Opinion Release 22-01

Yesterday, I ended my blog post with a few words about what we call in Texas Creative Lawyerin in the context of a Securities and Exchange Commission (SEC) enforcement action where there was zero fine and penalty due to the...more

Society of Corporate Compliance and Ethics...

Gary Kalman on Corruption and Compliance Programs

The playing field for anticorruption never stops changing, with new laws and new risks constantly arising. To help sort things out, and to gain his insight into other compliance challenges, we sat down with Gary Kalman,...more

Thomas Fox - Compliance Evangelist

A Primer on Extortion Payments

Yesterday, I posted a short primer on facilitation payments. Today, I want to take up another issue which embroils compliance officers from time to time; that being extortion payments. For compliance officers’ purposes,...more

Thomas Fox - Compliance Evangelist

What are Your Policies on Extortion Payments?

With the US Supreme Court holding that it is legal to politically extort any jurisdiction beneath you and the Trump Justice Department stating that is also now legal to lie to the FBI, I thought it would be a good time to...more

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