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Foreign Corrupt Practices Act (FCPA) Young Lawyers

Thomas Fox - Compliance Evangelist

First 100 Days of the Trump Administration and The FCPA – Same As It Ever Was

Over the weekend, we had the first 100 days of the Trump administration. To commemorate this constructed time for review of any new administration I gathered the Everything Compliance podcast panel of Mike Volkov, Jay Rosen,...more

Thomas Fox - Compliance Evangelist

Deep Dive Due Diligence: Part I – What is Level III Due Diligence?

There are many levels of due diligence investigation. In a multi-part series this week, I am going to focus on Level III, deep dive due diligence. I am joined in this exploration by Candice Tal, founder and Chief Executive...more

Thomas Fox - Compliance Evangelist

FCPA Compliance Report-Episode 313-Adam Davidson on Donald Trump's Worst Deal

In this episode, I visit with New Yorker reporter Adam Davidson, who penned an article in the New Yorker which looked at a hotel deal between the Trump organization and a family of Politically Exposed Persons (PEPs) in...more

Manatt, Phelps & Phillips, LLP

Corporate Investigations and White Collar Defense - July 2016

“Official Acts”—What They Are… and Are Not - Why it matters: On June 27, 2016, the Supreme Court decided McDonnell v. U.S., holding that, for purposes of the federal public corruption statutes, an “official act”...more

Skadden, Arps, Slate, Meagher & Flom LLP

"Cross-Border Investigations Update - June 2016"

This issue of Skadden’s semiannual Cross-Border Investigations Update takes a look at recent cases and enforcement trends, including proposed amendments to China’s commercial bribery law, the use in U.S. courts of compelled...more

Manatt, Phelps & Phillips, LLP

Corporate Investigations and White Collar Defense - June 2016

Eye on the Supreme Court—Corruption and Fraud Edition - Why it matters: This session, the Supreme Court has undertaken the review of numerous cases that raise thorny issues arising in the white collar context. In our...more

Thomas Fox - Compliance Evangelist

FCPA Compliance and Ethics Report-Episode 255-revising your Code of Conduct

In this episode, I discuss the considerations going into the revision of your Code of Conduct and how to move forward to do so. ...more

Morrison & Foerster LLP

Top Ten International Anti-Corruption Developments for April 2016

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

Morrison & Foerster LLP

Top Ten International Anti-Corruption Developments for March 2016

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

K&L Gates LLP

Are Your Company’s Legal, Due-Diligence, De-risking, or Compliance Obligations Impacted by the “Panama Papers”?

K&L Gates LLP on

In an unprecedented event earlier this week, 11.5 million files from the Panamanian law firm Mossack Fonseca were allegedly leaked. Assuming they are genuine, as appears to be the case, these “Panama Papers” offer a...more

Bracewell LLP

Improved U.S. - Cuba Relations Create Potential FCPA Risks for U.S. Companies Looking to Do Business There

Bracewell LLP on

The normalization of relations between the United States and Cuba offers potential lucrative business opportunities for companies that are prepared to meet Cuba’s unique corruption risks. On December 17, 2014, President...more

The Volkov Law Group

Doing Business in China Should Be “Scary”

The Volkov Law Group on

Lauren Connell, Managing Associate at The Volkov Law Group, joins us again for another posting on corruption risks in China. A little fear is healthy. It will keep you vigilant and aware. At this point if corporate...more

Thomas Fox - Compliance Evangelist

Doing Business in Cuba Under the FCPA – Part II

Today, I continue my exploration of doing business in Cuba from the Foreign Corrupt Practices Act (FCPA) perspective. Yesterday, I made clear that anyone you do business with in Cuba is going to be a foreign official under...more

Thomas Fox - Compliance Evangelist

Doing Business in Cuba Under the FCPA – Part I

I am back from a week of cultural and professional exchange in Cuba. It had been a lifelong dream of mine to go to Cuba and I hopped on the first trip I could enroll in after the travel for cultural exchanges were opened up...more

McGuireWoods LLP

The Olympus Debacle: Why Internal Whistleblowing is a Good Thing for Compliance

McGuireWoods LLP on

The U.S. Department of Justice announced last week that Olympus Corporation of the Americas (OCA) agreed to pay $646 million to resolve three cases relating to its longstanding practice to bribe doctors and hospitals in the...more

The Volkov Law Group

Olympus: A Culture of Bribery and Kickbacks

The Volkov Law Group on

When compliance officers read about a major Justice Department settlement action, we can all hear the collective sigh of relief – “Thank goodness, that did not happen here in my company.”...more

The Volkov Law Group

A Teaching Moment Inside VimpelCom’s Boardroom

The Volkov Law Group on

The VimpelCom FCPA settlement underscored the importance of Compliance 2.0 and the need to reform board deliberations and governance. No one can read the facts without shaking their heads and asking – what was the VimpelCom...more

McGuireWoods LLP

Key Takeaways From This Year’s Early FCPA Enforcement Actions

McGuireWoods LLP on

February has been a big month for U.S. Foreign Corrupt Practices Act (FCPA) enforcement. It started with the U.S. Securities and Exchange Commission (SEC) quietly resolving a string of relatively small matters. Then, at the...more

Thomas Fox - Compliance Evangelist

VimpelCom Final Thoughts

Today, I conclude my exploration of the VimpelCom Foreign Corrupt Practices Act (FCPA) enforcement action. As I said yesterday, this case will be studied for some time as a textbook example of bribery schemes used...more

BCLP

SEC Targets Insufficient Anti-Corruption Compliance Programs

BCLP on

The Securities and Exchange Commission’s (SEC) recent Foreign Corrupt Practices Act (FCPA) settlements focus on companies’ lack of sufficient anti-corruption compliance programs, which means, to the SEC, that the companies...more

Thomas Fox - Compliance Evangelist

Star Wars Week Part I – How do You Evaluate a Risk Assessment?

Today I begin a series of Star Wars themed blog posts to celebrate the upcoming release of the next entry in the Star Wars franchise, Episode VII – The Force Awakens. Please note that I will only use the first three movies,...more

Orrick, Herrington & Sutcliffe LLP

The World in US Courts - Orrick's Quarterly Review of Decisions Applying US Law to Global Business and Cross-Border Activities:...

We are pleased to announce the Summer 2015 issue of The World in US Courts: Orrick's Quarterly Review of Decisions Applying US Law To Global Business and Cross-Border Activities. This issue discusses 13 new decisions that...more

Thomas Fox - Compliance Evangelist

BNY Mellon and Lessons Learned In Hiring Family Members – Part II

In yesterday’s post I reviewed the Securities and Exchange Commission (SEC) Foreign Corrupt Practices Act (FCPA) enforcement action involving the Bank of New York Mellon Corporation (BNY Mellon) around its hiring of sons and...more

The Volkov Law Group

Cecil the Lion and Due Diligence Failures

The Volkov Law Group on

The “I didn’t know” defense is a tough one to sustain. Maybe you didn’t “know,” but should you have known? Were all the signs there but you looked the other way? Should you have asked more questions? Is it fair to infer by...more

Locke Lord LLP

The Foreign Corrupt Practices Act: At a Glance

Locke Lord LLP on

In this issue: - FCPA AT A GLANCE - THE ANTI-BRIBERY PROVISIONS OF THE FCPA - TO WHOM THE ANTI-BRIBERY PROVISIONS APPLY - THE PAYMENT ELEMENT - THE CORRUPT INTENT ELEMENT - WHO IS A...more

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