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
Sorry to start a four-part series with a reference to music from our long-ago past. The Four Tops sang the “Same Old Song, with a Different Meaning” (released in 1965). So, how does that relate to third-party risks? Well,...more
A Top 5 list should be viewed with suspicion — it is often just a headline grabbing posting with the clear purpose to gain readers’ attention. In defense, however, it is interesting to compare articles on risk rankings....more
The compliance community has long recognized the gaping hole in the Foreign Corrupt Practices Act (FCPA). As a supply side law, it criminalizes the payment of bribes, not the demand to pay a bribe or extortion. The gap was...more
The Justice Department has touted the upcoming wave of corporate prosecutions for criminal sanctions violation as the era of “The New FCPA.” DOJ’s reference is intended to communicate a strong message – companies are going to...more
Sanctions continue to be a dynamic area of regulation and enforcement. In its first year, the Biden Administration has already undertaken a number of different sanctions initiatives. The three examples below highlight the...more
Civil and criminal penalties levied against U.S. companies for trade violations are just the beginning of the potential unforeseen costs of doing business in the global marketplace. What cannot be quantified are the countless...more
The NFL has scored a new media deal spread across outlets from CBS, NBC, and Fox to ESPN and Amazon worth nearly $110 billion over 11 years, “nearly doubling the value of its previous contracts” and “cement[ing]” the league’s...more
Dear Friend of Snell & Wilmer: The past year brought significant changes across a variety of political, legal, and policy spheres, and the world of U.S. international trade law was no exception. This edition of the...more
I continue my exploration of the issues raised under the Foreign Corrupt Practices Act (FCPA) when doing or attempting to do business in Cuba. On Monday, I referred to the one person I am aware of you might consult for advice...more
Today, I continue my exploration of doing business in Cuba from the Foreign Corrupt Practices Act (FCPA) perspective. Yesterday, I made clear that anyone you do business with in Cuba is going to be a foreign official under...more