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
Legg Mason can finally close its books on the Gaddafi-era, Libyan bribery scandal. In June 2018, Legg Mason entered into a non-prosecution agreement with the Justice Department and agreed to pay $32 million for its role in...more
King’s back story of starting with the great psychedelic band Strawberry Alarm Clock and then moving to the Southern rockers Lynyrd Skynyrd, informs today’s blog post on the Legg Mason, Inc. (LM) Securities and Exchange...more
Sometimes it takes a large enforcement action to underscore basic and important anti-corruption compliance principles. The Société Générale enforcement action demonstrated two important principles – the dangers of a weak...more
Société Générale and Legg Mason carried out a massive bribery scheme to pay Gaddafi-era government officials in Libya in exchange for large investments by Libya government funds. In total, Société Générale and Legg Mason...more
In a one-two punch of FCPA enforcement actions, the Justice Department announced two related FCPA settlements involving Société Générale and Legg Mason for Gaddafi-era bribery payments to Libyan officials....more
With a wild ride of FCPA cases over the past week, Jay Rosen and I are back in the FCPA saddle again to take a look at some of the top compliance stories from the past week. 1. Société Générale S.A. becomes No. 5 in the...more
Legg Mason had engaged in a straight-forward bribery scheme and the perpetrators had actively engaged to hide it from the corporate headquarters. The bribery scheme involved Société Générale S.A. (SocGen) and the entity...more
The Department of Justice (DOJ) announced two Foreign Corrupt Practices Act (FCPA) enforcement actions earlier this week and the intertwined nature of these two enforcement actions informs today’s blog post....more
Major FCPA Enforcement Action - Including charges against the CEO and CFO for failing to prevent misconduct - In one of the largest FCPA settlements in history, hedge fund Och-Ziff Capital Management Group LLC...more
The Och-Ziff settlement has now set the stage for the Justice Department and the SEC to focus its enforcement eye on the private equity and hedge fund industry. The Och-Ziff action was initiated in response to the SEC’s...more
In one of the largest FCPA settlements in history, hedge fund Och-Ziff Capital Management Group LLC (“Och-Ziff”) recently resolved a long-running government inquiry by agreeing to $413 million in financial penalties and a...more
The Justice Department and the Securities Exchange Commission delivered a powerful FCPA enforcement message to private equity and hedge funds. Och-Ziff settled with the DOJ and SEC for total penalties of $412 million....more
It has been known for some time that the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) have been investigating investment banks over their dealings with the Libyan sovereign wealth fund, known as...more
FCPA enforcement efforts are not so hard to follow and predict – the government likes to provide advance warnings as an effective means of deterrence. Justice Department and SEC officials will often tell the public their...more