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 March 3, 2023, the Department of Justice (“DOJ”) issued long-awaited guidelines on how it will evaluate whether companies have implemented appropriate guidance and controls on the use of personal devices and third-party...more
In September 2022, the U.S. Department of Justice (DOJ) issued a memo announcing revisions to the DOJ’s corporate criminal enforcement policies and practices....more
Deputy Attorney General (DAG) Lisa Monaco’s September 15, 2022, memorandum on revisions to the Department of Justice’s (DOJ) Corporate Enforcement Policies (the Monaco Memo) reflects that preservation of business...more
DOJ’s dismissal last week of a Foreign Corrupt Practices Act case in Boston is the latest in a string of bad outcomes for the government due to discovery mishaps. While the government works to revise its discovery policies...more
On March 8, 2019, the U.S. Department of Justice announced an important change to its Foreign Corrupt Practices Act (FCPA) Corporate Enforcement Policy concerning one of the conditions — “appropriate retention of business...more
The United States government has a powerful new tool to gain access to data stored overseas – the CLOUD Act, which was enacted this spring. If you are a company based overseas, particularly if you use a cloud service provider...more
Focus on four areas to mitigate the danger of data transfer across borders - Cross-border data transfers are not only frequent, but often crucial components of everyday business. Today’s patterns of global data flow would...more
For many legal practitioners, Asia remains a legal challenge, “whether it’s the different data sources, the lack of familiarity with case law or an understanding of the legal landscape in different countries, from Hong Kong...more
In the ongoing and contentious litigation between Uber and Google's autonomous (self-driving) vehicle unit (Waymo v. Uber), allegations have arisen that one party has hidden relevant information, in part by use of...more
It is hard to imagine how prosecutors were able to bring cases before there was email communications. When I was a prosecutor, we looked for evidence in a lot of other sources, internal memos, calendars and other places where...more
With so much potentially at stake, the initial steps and strategic decisions taken in any company investigation are critical to setting the tone for a focused, credible and effective inquiry. This is paramount not only for...more