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The Foreign Corrupt Practices Act Dept. of Justice

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.

DOJ Issues New Policy Encouraging Self-Reporting FCPA Violations

by Bracewell LLP on

On November 29, 2017 the Deputy Attorney General of the U.S. Department of Justice (DOJ), Rod J. Rosenstein, announced a new FCPA enforcement policy that seeks to incentivize voluntary self-reporting by providing companies...more

This Week In Securities Litigation

by Dorsey & Whitney LLP on

The DOJ announced the formalization of a new FCPA cooperation policy built on the success of its Pilot Program. That program resulted in a significant increase in firm’s self-reporting and cooperating, the goal of the new...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

DOJ’s FCPA Corporate Enforcement Policy Creates Greater Certainty for Companies

The Foreign Corrupt Practices Act of 1977 (FCPA) makes it unlawful for certain classes of persons and entities to make payments to foreign government officials to assist in obtaining or retaining business. On November 29,...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

A Dialogue With Corporate Counsel: Skadden’s Seventh Annual Pharmaceutical and Medical Device Seminar

Panelists examined major enforcement actions from 2017 and identified key trends. Aggressive Enforcement With a Decrease in High-Dollar Settlements. Panelists noted that the Department of Justice (DOJ) continues its...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

DOJ's New FCPA Enforcement Policy Continues its "Carrot-and-Stick" Approach

by Jones Day on

The Situation: Companies that learn of Foreign Corrupt Practices Act ("FCPA") violations by employees or agents are faced with significant uncertainty as to whether the benefits and risks of self-disclosing the conduct to the...more

Rosenstein Announces Permanent FCPA “Pilot Program,” Presumption of Declination When Self-Reporting, but Difficult Choices Remain

by Ropes & Gray LLP on

On Wednesday, November 29, 2017, in remarks at the 34th International Conference on the Foreign Corrupt Practices Act (“FCPA”), Deputy Attorney General Rod J. Rosenstein announced a revised FCPA Corporate Enforcement Policy...more

DOJ Announces New FCPA Policy to Further Incentivize Corporate Voluntary Self-Disclosure and Cooperation

by Foley Hoag LLP on

The U.S. Foreign Corrupt Practices Act turned forty this year. The Department of Justice is marking that anniversary by announcing a new Corporate Enforcement Policy specific to FCPA matters. The new Policy makes explicit...more

Deputy Attorney General Rod Rosenstein Announces Revised FCPA Corporate Enforcement Policy

by Shearman & Sterling LLP on

On November 29, 2017, Deputy Attorney General Rod Rosenstein delivered remarks at the 34th International Conference on the Foreign Corrupt Practices Act (“FCPA”), in which he announced a revised FCPA Corporate Enforcement...more

Justice Department Revises FCPA Corporate Enforcement Policy

by Fox Rothschild LLP on

The Foreign Corrupt Practices Act is alive and well under the Trump administration and remains a top priority for the U.S. Department of Justice. Since 2016, the DOJ’s Fraud Section has resolved 17 criminal corporate...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

DOJ Announces Revised FCPA Corporate Enforcement Policy

by BakerHostetler on

On November 29, 2017, Deputy Attorney General Rod Rosenstein expanded upon the Department of Justice’s (“DOJ”) long-running efforts to encourage companies to self-disclose Foreign Corrupt Practices Act (“FCPA”) violations by...more

US Department of Justice Refines Incentives for Corporate Disclosure of Potential FCPA Violations

by Dechert LLP on

Speaking at a conference in Maryland on November 29, 2017, Deputy Attorney General Rod Rosenstein announced a revised Foreign Corrupt Practices Act (“FCPA”) Corporate Enforcement Policy (“CEP”). This policy builds on the...more

DOJ Deputy Attorney General Rod Rosenstein Announces FCPA Corporate Enforcement Policy

• The voluntary disclosure of a Foreign Corrupt Practices Act (FCPA) violation, “full cooperation” in an ensuing investigation, and timely and appropriate remediation, will create a presumption that the disclosing company...more

Building on Pilot Program, DOJ Announces New FCPA Corporate Enforcement Policy

by Morrison & Foerster LLP on

On November 29, 2017, Deputy Attorney General Rod Rosenstein announced a new “FCPA Corporate Enforcement Policy” (“Policy”) that extends and revises the FCPA Pilot Program. In his announcement, DAG Rosenstein explained that...more

FCPA Compliance Report-Episode 360, James Koukios on New FCPA Corporate Enforcement Policy

by Thomas Fox on

In this episode, I visit with Morrison and Foerster partner James Koukios on the Department of Justice (DOJ) new policy regarding Foreign Corrupt Practices Act (FCPA) enforcement. Last week, Deputy Attorney General Rod...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

DOJ Announces New FCPA Cooperation Policy

by Dorsey & Whitney LLP on

The Department of Justice announced a revised FCPA Corporate Enforcement Policy. The new policy, designed to enable the DOJ to efficiently identify and punish criminal conduct while encouraging voluntary disclosures of wrong...more

Expansion of FCPA “Pilot Program” is Good for Companies, but Heed the Fine Print

by McGuireWoods LLP on

Deputy Attorney General Rod Rosenstein’s Nov. 29 announcement that the Department of Justice FCPA “Pilot Program” will be permanently expanded is good news for companies that repeatedly faced the dilemma of whether or not to...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

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