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
Attention all compliance officers at large technology companies – have you checked your mail lately? Because you might find a letter from the Securities and Exchange Commission with FCPA risk written all over it....more
While DOJ had its biggest year in FCPA enforcement, OFAC quietly had a record year in enforcement. OFAC collected approximately $1.28 billion (yes, with a B) in 26 separate enforcement actions. That is quite an increase...more
Understanding the boundaries of legal privilege in corporate internal investigations is critical. When counsel, either internal or external, misunderstands these boundaries, the result can be disastrous....more
Companies will often rely on a network of distributors to help sell their products in emerging markets. From a business economics standpoint, engaging a distributor is often more cost efficient than investing in a sales...more
Fresenius Medical came close to earning a declination under the FCPA Corporate Enforcement Policy. Unfortunately, Fresenius’ effort fell short — but it came close. Fresenius Medical operates more than 3700 dialysis clinics...more
Believe it or not, life principles can be used in compliance, especially in due diligence. I always tell my kids that life has a way of setting priorities. As you get older, life becomes simpler and your priorities become...more
The SEC filed another settled action in which payments to health care professionals at state owned entities in China were alleged to be violations of the Foreign Corrupt Practices Act. Although the company furnished extensive...more
The Department of Justice and the SEC know they can push companies to expand and improve their anti-corruption compliance programs. They are well aware that the requirements set forth in their settlement documents, as well as...more
McDermott Will & Emery is pleased to offer “Distribution in China – Legal Issues*,” a one-stop resource covering distribution in China, including: The business models and legal structures most commonly used for...more
McDermott Will & Emery has a strategic alliance with MWE China Law Offices, a separate law firm based in Shanghai. "Distribution in China – Legal Issues” is a four-part series. Part I discussed the business models...more
This week we have focused on distributors and how a company might think through ranking the risk, performing due diligence on and, finally, how to manage distributors going forward. This was spurred on by a discussion that...more
Ed. Note-today we have a guest post by our colleague, William C. Athanas, a partner in the law firm of Waller Lansden Dortch & Davis, LLP. In the prior two posts, David Simon and myself posited different approaches to...more
Ed. Note-we continue our series on the risk analysis and assessment of distributors under the FCPA and management of that risk. Today, David Simon contributes a guest post where he articulates another approach to the risk...more
Ed. Note-David Simon is a partner at Foley and Lardner and Bill Athanas is a partner at Waller Lansden Dortch & Davis, LLP. Both have practices which include FCPA compliance. After my recent post on distributors under the...more
If there was ever a question that distributors were covered under the Foreign Corrupt Practices Act (FCPA), in 2012, the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) made it emphatically clear that...more