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
The end of the road for Roger Ng, the Goldman Sachs Investment Banker, who played a critical role in the Goldman Sachs 1 MDB Malaysia scandal, was not a pretty one. District Judge Margo Brodie gave Ng a severe sentence of...more
Each FCPA case provides valuable lessons in the mechanics of bribery schemes and the common techniques used by violators to secure funds and make illegal payments to foreign government officials. Criminal violators often act...more
Talk about a reminder of the past, Asante Berko, a former Executive Director in Goldman Sachs, recently was arrested in London on criminal FCPA charges arising from his involvement in a bribery scheme in Ghana....more
Eric T. Young welcomes Alixandra Smith, a deputy chief of the Criminal Division at the U.S. Attorney’s Office for the Eastern District of New York. The two discuss the Department of Justice’s renewed approach about corporate...more
The scandal emanating from the 1 Malaysia Development Berhad fund (1MDB) continues to ripple through criminal law enforcement and criminal prosecutions. ...more
There is much to be learned from reviewing the wreckage of a major Justice Department enforcement action. It is helpful to identify these themes, analyze the conduct and reasons for the violation, and identify helpful...more
In 2020, the Justice Department did not insist on the appointment of any independent compliance monitors. The year before, in 2019, DOJ insisted on the appointment of three independent corporate monitors – MTS...more
Bear with me for a second, but remember Presidential Candidate Romney’s statement in 2011 that “Corporations are people.” Starting with that premise, my so-called “Person” of the Year award for 2020 goes to, drumroll . . ....more
Well, it is that time again. I get to put on my Carnac the Magnificent Hat and offer my FCPA predictions for 2021. I should get a pass on my 2020 FCPA Predictions posting because no one could have anticipated the COVID-19...more
The Justice Department and the Securities and Exchange Commission had another record year of enforcement. In fact, the last four years of FCPA enforcement included two years of record enforcement – 2019 and 2020. After...more
In this episode, I am joined by Eric Young, recently retired long-time compliance professional. We explore an under-looked aspect of the Goldman Sachs FCPA enforcement action; the independent enforcement actions by the...more
The breadth of Goldman Sachs’ corruption in the recent DOJ and SEC FCPA enforcement action underscored the important global goal of reducing corruption. It goes without saying – corruption has a pernicious impact on economic...more
We conclude our exploration of The Goldman Sachs Group, Inc. (Goldman Sachs) Foreign Corrupt Practices Act (FCPA) settlements and related enforcement action, literally across the globe, from the state of New York to...more
We continue our exploration of The Goldman Sachs Group, Inc. (Goldman Sachs) Foreign Corrupt Practices Act (FCPA) settlements and related enforcement action, literally across the globe, from the state of New York to...more
On October 22, 2020, the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) announced the coordinated $2.9 billion resolution of a Foreign Corrupt Practices Act (FCPA) enforcement action against The...more
It would be a mistake to think that the $2.9 billion settlement Goldman Sachs Group Inc. has agreed to pay in order to resolve allegations of widespread bribes to government officials in Malaysia and the United Arab Emirates...more
Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt and Tom go into the weeds to...more
Goldman Sachs now sits atop all charts with the largest US FCPA bribery penalty, totaling approximately $2.9 billion. The second largest is Ericsson’s 2019 FCPA settlement for $1 billion....more
The Justice Department finally closed out its investigation of Goldman Sachs’ massive bribery scheme involving Malaysia’s 1MDB fund. The case is now the largest in US FCPA history (based on its payment to DOJ and related US...more
A resolution in the biggest Foreign Corrupt Practices (FCPA) corruption scandal was announced last week, involving The Goldman Sachs Group, Inc., (Goldman Sachs) and its subsidiary Goldman Sachs (Malaysia) Sdn. Bhd. (GS...more
In this first live recording of Everything Compliance, an abbreviated crew of Matt Kelly, Jay Rosen and Tom Fox provide their initial thoughts and questions on the Goldman Sachs 1MDB FCPA settlement....more
The Google antitrust waiting game wrapped on Tuesday with the DOJ filing a federal D.C.-based lawsuit against the Alphabet unit, accusing the company “of using several exclusive business contacts and agreements to lock out...more