FCPA Survival Guide - Step 8 - Investing in Compliance
Episode 328 -- Sanctions Enforcement Risks and Redlines
FCPA Survival Guide: Step 3 - Extensive Remediation
Episode 324 -- Third-Party Risks and Sanctions Compliance
Compliance Tip of the Day – Compliance Lessons from the Albemarle FCPA Enforcement Action
FCPA Survival Guide: Step 1 - Self-Disclosure
All Things Investigations: Compliance Lessons from Gunvor and Trafigura Enforcement Actions
Corruption, Crime & Compliance: Deep Dive into The Trafigura FCPA Settlement
Episode 317 -- A Deep Dive into the Trafigura FCPA Settlement
What's Going on with FCPA?
Episode 316 -- DOJ Announces New Whistleblower Policy
Compliance into The Weeds: Trafigura FCPA Enforcement Action
Corruption, Crime & Compliance: Deep Dive into The Gunvor FCPA Settlement
Episode 314 -- A Deep Dive into Gunvor's FCPA Settlement
Corruption, Crime & Compliance: DOJ’s Shifting Approach to Recidivism and Self-Disclosure
Episode 311 -- Tom Fox on FCPA Enforcement: Self Disclosure and Recidivism
Episode 307 -- Sanctions Enforcement Review and Predictions for 2024
Episode 305 -- Deep Dive into SAP FCPA Settlement
Compliance Into The Weeds: The SAP Foreign Corrupt Practices Act Enforcement Action
Episode 300 -- Deep Dive into DOJ FCPA Settlement with Two U.K. Reinsurance Companies for Bribery in Ecuador
On September 27, 2022, U.S. District Judge Kevin McNulty of the District of New Jersey dismissed a consolidated derivative action allegedly brought on behalf of Cognizant Technology Solutions Corporation against certain...more
Securities Class Action Against Swiss-Based Company Dismissed On Forum Non Conveniens Grounds; Second Circuit Finds Strong Inference of “Conscious Recklessness” In Allegations And Reverses Dismissal of Securities Suit Against...more
Last week Juniper Networks, Inc. (JNPR) resolved their long-standing Foreign Corruption Practices Act (FCPA) enforcement action by settling with the Securities and Exchange Commission (SEC) via a Cease and Desist Order...more
As anticipated, securities class action filings remained high in 2018, with more than 400 filings in federal court, and the number is expected to remain high in 2019. While the total number is slightly less than in 2017, it...more
This blog post will begin a multi-part exploration of the Petróleo Brasileiro S.A. – Petrobras (Petrobras) Foreign Corrupt Practices Act (FCPA) enforcement action. The action was a stunning reminder of the costs of endemic...more
When a public company resolves a Foreign Corrupt Practices Act (FCPA) investigation by either the U.S. Department of Justice (DOJ) or Securities and Exchange Commission (SEC), private litigation by investors under the...more
On March 30, 2018, the United States District Court for the Southern District of New York dismissed with prejudice a class action complaint against Embraer S.A. (“Embraer” or the “Company”) and several of its officers,...more
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 from the past month, with links to primary...more
ANTICORRUPTION DEVELOPMENTS - Mega International Commercial Bank Co. Ltd. Fined $29 Million - On January 17, 2018, the U.S. Federal Reserve Board assessed Taiwan based bank Mega International Commercial Bank Co. Ltd. a...more
In this newsletter, we provide a snapshot of the principal Asian, US, European and selected international governance and securities law developments of interest to Asian corporates and financial institutions. ...more
ANTICORRUPTION DEVELOPMENTS - Mega International Commercial Bank Co. Ltd. Fined $29 Million - On January 17, 2018, the U.S. Federal Reserve Board assessed Taiwan based bank Mega International Commercial Bank Co. Ltd....more
This quarter’s issue includes summaries and associated court opinions of selected cases principally decided between August 2017 and October 2017....more
While the Journal considers the ever-growing list of headaches for Khosrowshahi, including a new federal bribery probe over potential Uber FCPA violations....more
In In re Petrobras Securities Litigation, the Second Circuit Court of Appeals recently issued an opinion regarding the standards for certifying a class involving foreign securities. Petrobras is a multinational Brazilian gas...more
On January 19, 2017, the Western Union Company (“Western Union” or the “Company”) entered into a deferred prosecution agreement (“DPA”) with the Department of Justice (“DOJ”), in which Western Union admitted to willful...more
IN THE SPOTLIGHT - - SEC Sanctions Unregistered EB-5 Investments Broker SECURITIES - - FINRA to Assess Member Firms’ Culture - SEC Seeks Fund Responses to Distribution-In-Guise Guidance ...more
Budget hearings were a focus this week as the Chair of the SEC and Chairman of the CFTC visited Capitol Hill. Both sought substantial increases, requesting more money for technology, inspections and enforcement. While the...more
The Foreign Corrupt Practices Act was a key focus this week. The DOJ announced a new one year Pilot Program which holds the promise of a significant reduction in penalties if the firm self-reports and takes a series of steps....more
Latest Healthcare False Claims Act Roundup and Top 3 Best Practices to Reduce Exposure - As the legal landscape in healthcare becomes increasingly complex, healthcare companies that receive federal program funds face...more
High speed trading and insider trading were key topics this week. Author Michael Lewis released a new book on high speed trading and, in an interview claimed the markets are “rigged.” The Commission focused on insider...more
In This Issue: - AUDITOR LIABILITY - CLASS ACTIONS - CONFIDENTIAL WITNESSES - DEMAND FUTILITY - DERIVATIVE LITIGATION - FEDERAL TORT CLAIMS ACT - FOREIGN CORRUPT PRACTICES ACT - INSIDER TRADING...more
Upon learning that his obituary had been published in the New York Times, Mark Twain famously quipped, “Reports of my death have been greatly exaggerated.” The same can be said about class action lawsuit filings after the...more
New legal ground is expected to be broken this year in areas of importance to companies and their directors, officers and executives. We see those developments coming from around the globe and defining the litigation...more