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
One of the biggest changes in the 2020 FCPA Resource Guide, 2nd edition, is the addition of a new Hallmark, entitled, Investigation, Analysis, and Remediation of Misconduct, which reads in full...more
This is not your typical FCPA enforcement action Lessons Learned column. Instead, Ericsson’s breach of its DPA presents a laundry list of internal investigation errors – as a practitioner in this area, this is the nightmare...more
Ideal for practitioners who have some compliance knowledge and are ready for a deeper dive, SCCE’s Basic Compliance & Ethics Academy provides comprehensive, classroom-style training in the essentials of managing a compliance...more
Are you looking to better… - Support, enhance, and manage a compliance and ethics program? - Mitigate risk within your organization? - Understand the components of effective program infrastructure? SCCE’s Basic...more
Are you looking to better... - Support, enhance, and manage a compliance and ethics program? - Mitigate risk within your organization? - Understand the components of effective program infrastructure? SCCE’s Basic...more
Senior Managing Directors Scott Moritz, FTI Consulting, and Michael Archibald continue to discuss how to bring order to the chaos in the early days of an FCPA investigation and avoid mortgaging the company's future in the...more
Our Basic Academies are ideal for professionals with some compliance knowledge and experience who are ready to support, enhance and manage a comprehensive compliance program. They are taught by compliance professionals,...more
The call, email or tip comes into your office; an employee reports suspicious activity somewhere across the globe. That activity might well turn into a FCPA issue for your company. As the CCO, it will be up to you to begin...more
I am nearing the end of a multi-part exploration of the Major League Baseball (MLB) investigation into allegations that the Houston Astros engaged in a multi-year scheme to steal signs and signals from opposing teams. ...more
Quad/Graphics, a Wisconsin print and digital marketing company agreed to pay the SEC almost $10 million to settle FCPA charges for foreign bribery violations in Peru and China. ...more
The European Union (“EU”) recently has grappled with a series of massive money laundering scandals and strategized about how to more effectively combat international money laundering and corruption. Generally, the EU has...more
The Justice Department has been criticized on numerous occasions about its approach to criminal investigations and prosecutions. In a recent decision, the chief judge in the Eastern District of New York criticized DOJ for...more
The big one finally is resolved. The long-awaited Walmart Inc. (Walmart) Foreign Corrupt Practices Act (FCPA) enforcement action was announced yesterday. This massive case came in with multiple documents, a long list of...more
Fresenius Medical, the largest supplier of dialysis equipment and services agreed to pay $231 million to the Justice Department and the SEC to resolve FCPA violations in 17 countries in Africa, the Middle East and Europe....more
Yesterday, I considered four questions which the Department of Justice (DOJ) may ask Goldman Sachs. Today I want to consider what the company must show under the FCPA Corporate Enforcement Policy....more
• Four years ago, Brazilian authorities began Operation Car Wash, a wide-ranging and still ongoing corruption and money laundering investigation that has spanned 11 countries. • The fallout continues with a recent U.S....more
This blog post concludes my multi-part exploration of the Petróleo Brasileiro S.A. – Petrobras (Petrobras) Foreign Corrupt Practices Act (FCPA) enforcement action. Today we consider the stunning result achieved by Petrobras –...more
ANTICORRUPTION DEVELOPMENTS - $34 Million SEC Settlement for Legg Mason - On August 27, 2018, the Securities and Exchange Commission (SEC) announced that Legg Mason Inc. will pay more than $34 million to settle an...more
The United States Department of Justice, the U.S. Securities and Exchange Commission, and non-U.S. governments and agencies have recently emphasized their continued commitments to pursuing both corporate and individual...more
Properly Scoped Investigation by Qualified Personnel – How has the company ensured that the investigations have been properly scoped, and were independent, objective, appropriately conducted, and properly documented? These...more
Your company should have a detailed written procedure for handling any complaint or allegation of bribery or corruption, regardless of the means through which it is communicated. The mechanism could include the internal...more