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
Attention all compliance officers at large technology companies – have you checked your mail lately? Because you might find a letter from the Securities and Exchange Commission with FCPA risk written all over it....more
There are many international and Asia-based investors looking to invest in companies in the US for both strategic and commercial reasons, and in return they offer attractive sources of funding. Often, financial investments...more
U.S. Securities and Exchange Commission (SEC) Chair Gary Gensler outlined a vigorous enforcement approach in his keynote remarks at the annual Securities Enforcement Forum. In a clear reference to cryptocurrencies and tokens,...more
The Annual Gathering for the Global Anti-Corruption Community - Exclusive Interview with President of Microsoft at FCPA DC - The world has reached an inflection point in which digital technology is being used as both a...more
In the following article we will discuss the current developments and trends for 2020 and outline what EU-based companies with a US presence should look out for in 2020 regarding US white-collar and compliance trends in the...more
Last week, Airbus SE (Airbus) settled a long-standing corruption scandal by agreeing to enforcement actions in three countries; France, the United Kingdom and the US. The matter involved a massive, worldwide, long running...more
In a blockbuster case, the Justice Department announced a global settlement with Airbus SE, a manufacturer of civilian and military aircraft, under which Airbus agreed to pay over $4 billion (yes, with a “B”) to resolve...more
ANTICORRUPTION DEVELOPMENTS - Telecommunications Company Fined $12 Million for FCPA Violations - On August 29, 2019, The Securities and Exchange Commission (SEC) instituted ceaseand-desist proceedings against...more
When it comes to the Justice Department and reading the tea leaves, I often rely on a very obvious point – DOJ tells you in advance what it is planning and then executes its plan. This has been true in the FCPA arena,...more
Initially, it would not seem that much was new or different about the Microsoft FCPA enforcement action but through this exploration, I think some clear lessons have emerge. The first is around internal controls. Here there...more
Microsoft’s bribery and controls violations reflect significant risks facing companies that rely on distributor and reseller networks to sell their products. Companies often enter and operate in emerging markets through...more
Continuing our use of great drum solos to consider the Microsoft Foreign Corrupt Practices Act (FCPA) enforcement action, today we consider what Microsoft did to obtain their result. We have previously considered the...more
Microsoft finally resolved its FCPA enforcement action with a whimper. Notwithstanding prior suggestions that Microsoft’s investigation uncovered global conduct, Microsoft’s liability focused primarily on Microsoft’s conduct...more
Microsoft Hungary agreed to pay approximately $8.5 million to the DOJ. Together with the amounts paid to the SEC in profit disgorgement, the total is just over $25 million. Microsoft Hungary received a 25% discount off the...more
“Microsoft’s subsidiary in Hungary provided discounts on software licenses to its resellers, distributors and other third parties. Instead of passing on the discounts to Microsoft’s government customers, the discounts were...more
Tech companies of U.S. origin tend to have compliance programs focused on U.S. laws, including the Foreign Corrupt Practices Act (the "FCPA") and relevant tax and labor laws. The UK has enacted laws covering bribery and...more
Tariffs targeting Chinese imports into the United States garnered headlines throughout 2018. However, during the latter part of the year, the U.S. government more quietly initiated efforts that in 2019 and beyond could be...more
ANTICORRUPTION DEVELOPMENTS - DOJ Files Superseding Indictment in Haitian Port Corruption Plot - On October 30, 2018, the U.S. Department of Justice (DOJ) filed a superseding indictment in the District of Massachusetts...more
Last year, a group of U.S. military veterans and the relatives of troops killed in Iraq filed a lawsuit against several large international pharmaceuticals, accusing them of aiding and abetting terrorism by selling products...more
In the ongoing and contentious litigation between Uber and Google's autonomous (self-driving) vehicle unit (Waymo v. Uber), allegations have arisen that one party has hidden relevant information, in part by use of...more
Taking over as editors of Holland & Knight’s Government Contracts Blog has been a labor, but it has been a labor of love. Like the rest of the Government Contracts Team, we are passionate about staying on top of the latest...more