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The Foreign Corrupt Practices Act Corruption

The Foreign Corrupt Practices Act is a United States Federal law enacted in 1974 to create transparency and prevent bribery for U.S.-based corporations conducting business overseas.

When the Well-Intentioned Holiday Gift Crosses the Line

Sending the wrong gift to the wrong person could leave a company facing bribery charges. During the holiday season, we naturally want to acknowledge and thank our clients and vendors. Today, however, with stricter...more

Pushing Ethics and Compliance Programs in the New FCPA Corporate Enforcement Policy

by Michael Volkov on

The Justice Department’s aggressive enforcement program, particularly in the FCPA arena, has been the primary impetus to the growth and empowerment of the corporate compliance function. The Justice Department and SEC’s FCPA...more

Compliance Under the New FCPA Enforcement Policy – Final Thoughts

by Thomas Fox on

Over the past few posts I have been exploring the Department of Justice’s (DOJ) new policy regarding Foreign Corrupt Practices Act (FCPA) enforcement. Deputy Attorney General Rod Rosenstein, in a speech, called it the FCPA...more

Takeaways from the 34th International Conference on the Foreign Corrupt Practices Act

by K&L Gates LLP on

At the 34th International Conference on the Foreign Corrupt Practices Act held last week in Washington, D.C., industry executives, members of the defense bar, and regulators examined developments in the enforcement of the...more

Dorsey Anti-Corruption Digest - December 2017

by Dorsey & Whitney LLP on

Deputy Attorney General Rod Rosenstein announced the addition of a new Department of Justice (DOJ) Foreign Corrupt Practices Act (FCPA) policy, titled the FCPA Corporate Enforcement Policy. The new policy, which was...more

New FCPA Enforcement Policy Ends the Compliance Defense Debate

by Thomas Fox on

As I continue my exploration of the new Department of Justice (DOJ) policy regarding Foreign Corrupt Practices Act (FCPA) enforcement, the FCPA Corporate Enforcement Policy (Policy), one of the things that struck me was the...more

Compliance Under the New FCPA Enforcement Policy – Clarification and Consolidation

by Thomas Fox on

Last week, the Department of Justice (DOJ) premiered a new policy regarding Foreign Corrupt Practices Act (FCPA) enforcement. Deputy Attorney General Rod Rosenstein, in a speech, called it the FCPA Corporate Enforcement...more

Compliance Under the New FCPA Enforcement Policy – Compliance Expertise

by Thomas Fox on

Last week, the Department of Justice (DOJ) premiered a new policy regarding Foreign Corrupt Practices Act (FCPA) enforcement. Deputy Attorney General Rod Rosenstein, in a speech, called it the FCPA Corporate Enforcement...more

SBM Offshore Finally Reaches the Finish Line and Settles FCPA Case for $238 Million

by Michael Volkov on

In a follow-on prosecution and end to a twisted investigation and enforcement path, SBM Offshore agreed to settle an FCPA enforcement matter for $238 million (including a $500,000 criminal fine and $13.2 million forfeiture)....more

Compliance Under the New FCPA Enforcement Policy – Root Cause Analysis

by Thomas Fox on

Last week, the Department of Justice (DOJ) premiered a new policy regarding Foreign Corrupt Practices Act (FCPA) enforcement. Deputy Attorney General Rod Rosenstein, in a speech, called it the FCPA Corporate Enforcement...more

Let's Have A Really Uncomfortable Conversation

Having recently returned from three weeks of corporate engagements and conferences across nine time zones, I should be exhausted, but instead I’m exhilarated. Originally published on the FCPA Blog, www.fcpablog.com. ...more

Five Key Takeaways from DOJ’s New FCPA Corporate Enforcement Policy

by Michael Volkov on

In a significant FCPA enforcement development, DOJ’s Deputy Attorney General (“DAG”) Rod Rosenstein last announced the implementation of a new FCPA Corporate Enforcement Policy. The announcement was not a surprise based on...more

Cross-Border Investigations Update - November 2017

This issue of Skadden’s semiannual Cross-Border Investigations Update takes a close look at recent cases, regulatory activity and other key developments, including new U.K. reporting obligations for sanctions violations,...more

The New FCPA Corporate Enforcement Policy – A Step Forward for Compliance

by Thomas Fox on

On Wednesday, the Department of Justice (DOJ) premiered a new policy regarding Foreign Corrupt Practices Act (FCPA) enforcement. Deputy Attorney General Rod Rosenstein, in a speech, called it the FCPA Corporate Enforcement...more

Red Notice Newsletter - November 2017

ANTICORRUPTION DEVELOPMENTS – SBM Offshore N.V. Agrees to Pay $238 Million to Resolve DOJ FCPA Enforcement Action - On November 29, 2017, SBM Offshore N.V. (SBM), a Netherlands based company specializing in the...more

Top Ten International Anti-Corruption Developments for October 2017

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 from the past month, with links to primary...more

7 Key Takeaways: Bribery & The Boardroom

Kilpatrick Townsend Partner Joe Dowdy recently gave a presentation at the Charlotte Chapter of the Association of Corporate Counsel that addressed the enforcement of high-profile federal criminal laws rooted in bribery,...more

The Economic Costs of Corruption

by Thomas Fox on

In a truly extraordinary article in the New York Times (NYT), columnist Thomas L. Freidman opened the article on his interview with Crown Prince Mohammed bin Salman (MBS) with the following, “I never thought I’d live long...more

'The Chickenshit Club' - Book Review and Author Interview

by Thomas Fox on

'The Chickenshit Club' is the most important book that every Chief Compliance Office, General Counsel, and compliance practitioner needs to read. Here's a review and interview with its author....more

Commercial Division Dismisses Derivative Lawsuit After Board Rejects Shareholder Demand

The decision to bring a lawsuit on behalf of a corporation is entrusted to the corporation’s board of directors. A shareholder may not maintain a derivative lawsuit on behalf of a corporation without first making a demand on...more

DOJ Continues Run on Individual FCPA Criminal Prosecutions

by Michael Volkov on

The Department of Justice announced criminal FCPA charges against two individuals in connection with bribery payments to foreign officials in Chad and Uganda. The Justice Department’s announcement occurred on the heels of...more

Compliance Needs the Human Element

by Thomas Fox on

The key begins with leadership, where top management needs “to define the corporate culture and standards of behaviour, and improve capabilities in technology and processes. They also need to build trust among customers,...more

FCPA Violators Beware—SEC To Double Down On Enforcement

The SEC has signaled plans to double down on its FCPA enforcement efforts and speed up FCPA investigations. On November 9, 2017, Steven Peikin, Co-Director of the SEC’s Enforcement Division, delivered a speech at New York...more

Cain Takes the Reins as Chief of SEC’s FCPA Unit

by Moore & Van Allen PLLC on

With the official announcement that Charles Cain will replace Kara Brockmeyer as head of the SEC’s Foreign Corrupt Practices Act (FCPA) Unit, it is more likely that we will see a return to the enforcement trends and outcomes...more

The FCPA Week That Was — Seven Individuals Charged for FCPA Violations

by Michael Volkov on

To all the “nattering nabobs of negativity” concerning FCPA enforcement, the US Justice Department responded with a resounding message – not only is FCPA enforcement here to stay, but individual violators are on DOJ’s radar...more

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