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 7, 2024, Deputy Attorney General Lisa Monaco announced the Department of Justice (DOJ) would release a new whistleblower rewards program for civil and criminal forfeitures. On August 1, 2024, DOJ did just that—as the...more
The Nutter Securities Enforcement Update is a periodic update of noteworthy recent securities enforcement activity, settlements, decisions, and charges. We provide brief summaries that highlight recent enforcement action...more
Albemarle Corporation (Albemarle), a specialty chemicals manufacturing company located in Charlotte, North Carolina, agreed to pay more than $218 million to settle FCPA investigations with DOJ and the SEC stemming from...more
On January 31, 2020, the Department of Justice (“DOJ”) agreed to resolve allegations that Airbus SE (“Airbus”), a France-based aerospace company, used third-party business partners to bribe government officials and airline...more
To our bad guys, 2019 was a year flush with hope and opportunity; it ended with recidivism, more misery from Venezuela, a charlatan, an Okie who pulled a multi-million dollar fast-one on Chesapeake and, as in years past, a...more
On December 13, 2019, the US Department of Justice (DOJ) announced a revised Export Control and Sanctions Enforcement Policy for Business Organizations (Revised EC/S Policy), clarifying its prior guidance on voluntary...more
The US Department of Justice (DOJ) is increasingly using the money laundering statute to prosecute individuals in corruption and bribery cases. The Foreign Corrupt Practices Act (FCPA) is the primary statute prohibiting...more
Settlement Applies to $700 Million in Luxury Assets; Law Firms Obtain a Carve-Out - Last week, the Justice Department announced a massive settlement in the 1Malaysia Development Berhad (“1MDB”) case, a matter implicating...more
As reported by Byron Tau and Aruna Viswanatha in the Wall Street Journal (WSJ), “Jho Low, the businessman-turned-fugitive accused of masterminding a multibillion-dollar fraud involving Malaysia’s sovereign-wealth fund, agreed...more
Proposed Legislation Creates Rewards Program for Whistleblowers of Foreign Government Corruption - Third Post in a Three-Post Series - Newly proposed legislation, if passed, will authorize a whistleblower program for...more
• 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
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
Sweden-based Telia Company AB has agreed to pay $965 million to settle Foreign Corrupt Practices Act (FCPA) charges with the Department of Justice (DOJ) and Securities and Exchange Commission (SEC). U.S. v. Telia Co., No....more
Keeping ahead of global anti-corruption trends is critical in today’s business markets. The Dorsey Anti-Corruption Digest, which puts global trends at your fingertips, puts you ahead. The deep experience of the Dorsey...more
ANTICORRUPTION DEVELOPMENTS - U.K. Opens Corruption Investigation of Rio Tinto over Guinea Operations - On July 24, 2017, the United Kingdom’s Serious Fraud Office (SFO) announced that it had opened an investigation into...more
The Department of Justice (DOJ) ended its probe of Net1 UEPS Technologies, according to SEC filings from the South African-based payment processing company. The company received a declination from the Securities and Exchange...more
In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international anti-corruption developments from the past month, with links to primary...more
The U.S. Department of Justice (DOJ) on June 16, 2017, announced its first declination of 2017 and the closing of its investigation of Linde North America Inc. and Linde Gas North America LLC (collectively, Linde) concerning...more
DC Partner Mark Sere and DC Senior Associate Kristin Robinson have presented a webinar providing a mid-year update on the FCPA. In it, Mark and Kristin read the tea leaves on whether the Trump Administration was going to be...more
This issue of Skadden’s semiannual Cross-Border Investigations Update looks at Brexit’s impact on corporate crime and investigations, the U.S. DOJ’s increased use of forfeiture actions with international implications, current...more
I have spent this week reviewing the many lessons that can be garnered by the compliance practitioner from the VimpelCom Foreign Corrupt Practices Act (FCPA) resolution. However, there is one additional follow on from the...more
The Department of Treasury’s Office of Foreign Asset Control continues to ramp up sanctions enforcement. Even with the likely relaxation of the Iran and Cuba sanctions, OFAC has been continuing its aggressive enforcement...more