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
Publicly announced Foreign Corrupt Practices Act (FCPA) enforcement activity in 2023 did not return to the levels seen a few years ago, as indicated by both the total number of cases against corporate and individual...more
In March 2023 there were two days of speeches from the DOJ which added to the compliance complexity. The speeches were made by Deputy Attorney General (DAG) Lisa Monaco (2023 Monaco Speech) and Assistant Attorney General...more
Over the past several blog posts, I have been exploring the Albemarle FCPA enforcement action. We have explored in some detail the DOJ Non-Prosecution Agreement (NPA) and the SEC Administrative Order(Order). In this final...more
Executive compensation and the use of personal devices and ephemeral messaging are the key focus areas of new U.S. Department of Justice policies and guidance. We consider the changes and how companies should respond....more
With all eyes turning to 2023, recent Department of Justice (DOJ) corporate enforcement policy changes and clarifications hint at what can be expected from the DOJ in the year ahead. In September, Deputy Attorney General...more
This Hallmark was significantly expanded in both the 2019 Guidance and the FCPA Corporate Enforcement Policy. And in so doing, the DOJ has increased the prestige, authority and role of both the CCO and corporate compliance...more
I was recently having breakfast with a colleague and we were discussing the Department of Justice’s (DOJ) Compliance Counsel Hui Chen and what we believe to be the positive impact she has had on the compliance community,...more
May 4th is universally recognized (at least in the universe I inhabit) as Star Wars Day. According to Wikipedia, “May 4 is called Star Wars Day because of the popularity of a common pun spoken on this day. Since the phrase...more
Surf music is certainly an under-rated rock and roll genre. One of my favorites is The Trashmen’s Surfin’ Bird. It reached Number 4 on the Billboard Chart in 1963. I happened to hear it recently when I was reading about some...more
In a move that will surprise no regular reader here, Starboard Value has announced plans to put up its own slate of directors for Yahoo in an attempt to oust its “entire incumbent board” – NYTimes and WSJ... The Deal...more
In a burst of post-Labor Day energy, the SEC filed a number of significant actions. Those include a series of actions arising out of the audit failure by BDO; actions centered on a financial fraud at an on-line lender; cases...more