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
The Nutter Securities Enforcement Update is a periodic update of noteworthy recent securities enforcement activity, settlements, decisions, and charges. We provide brief summaries that highlight recent enforcement action...more
There are some things you learn best in calm, and some in storm. Willa Cather I know I sound like a broken record. The Justice Department’s white collar criminal enforcement has been trending down over the last few...more
The U.S. Attorney's Office for the Southern District of New York (SDNY) on Jan. 10, 2024, announced a Whistleblower Pilot Program (Program) that it is presenting as another "tool in [the SDNY's] toolkit" that could unearth...more
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
Blockchain presents unprecedented challenges around national security. This is true not only for the federal government, but also for businesses in the private sector. From cross-border transactions involving cryptocurrency...more
One of your employees working overseas emails you with great news – they’re about to close a $50 million sale with a new customer. They tell you everything looks great, but there’s just one thing. The local political party...more
There appears to be a bit of a lull in corporate prosecutions lately. The big banner cases tend to involve crypto firms rather than household names. There are a few significant settlements, such as in opioid cases, but we...more
On January 17, Assistant Attorney General Kenneth A. Polite, Jr. delivered remarks at Georgetown University Law Center, during which he announced changes to the DOJ’s Criminal Division Corporate Enforcement and Voluntary...more
Federal prosecutors enjoy flipping through the United States Criminal Code, 18 U.S.C. §§ 1 et seq., to pick out tools to charge defendants. Over the last ten years, DOJ’s reliance on criminal charges in FCPA cases has...more
Due to the impact of the COVID-19 pandemic, and the change in presidential administrations in the United States in January 2021, US enforcement of the Foreign Corrupt Practices Act (FCPA) declined in 2021. However, we...more
The U.S. Biden administration has announced a detailed new anti-corruption strategy, naming corruption as a core national security interest....more
On December 6, 2021, the Biden administration announced a sweeping new anti-corruption strategy. The “United States Strategy on Countering Corruption” (the SCC) follows President Biden’s declaration this summer, in a June...more
On 1 November 2021, the independent Committee on Standards in Public Life published a report recommending sweeping changes to lobbying rules in the UK. The Committee’s 103-page report contains resounding criticisms of the...more
In this episode, we examine how two criminal defendants are aiming to leverage parallel FCPA investigations by the SEC and the DOJ to build their defense. We’ll also offer our thoughts on the SEC’s new (and improved?)...more
In a novel and aggressive move likely aimed at garnering goodwill with federal regulators, Venezuelan state-owned entity CITGO Petroleum Company (“CITGO”) has sued its former agent for harm CITGO alleges was caused by the...more
A ruling issued on Wednesday, February 26 by a Connecticut federal court details the type of control necessary to find that a foreign national acted as an agent of a U.S. domestic concern for purposes of falling within the...more
This year, 2020, has been an enforcement year opening with billion-dollar settlements: first, Airbus settled FCPA charges for $4 billion, and now Wells Fargo for $3 billion. What a start to an enforcement year!...more
In the fourth quarter of 2019, U.S. enforcement authorities sustained efforts to prosecute individuals violating U.S. anticorruption laws in matters related to Latin America, while authorities in Latin America, including in...more
Last week, a jury found a former executive of a French multinational company guilty of violating the Foreign Corrupt Practices Act, money laundering, and conspiracy in connection with alleged bribery in Indonesia....more
The Foreign Corrupt Practices Act (FCPA) prohibits payment of bribes to foreign officials to assist with obtaining or retaining business. It also requires companies whose securities are listed in the US to make and keep...more
Tech companies of U.S. origin tend to have compliance programs focused on U.S. laws, including the Foreign Corrupt Practices Act (the "FCPA") and relevant tax and labor laws. The UK has enacted laws covering bribery and...more
On Sept. 9, 2015, then-Deputy Attorney General Sally Yates issued a memo requiring federal prosecutors to investigate any individuals responsible for illegal corporate conduct before settling a case. This applied to both...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