Wicked Coin: FIFA: Soccer, Scandal, and Sportswashing
Episode 339: Four Sanctions Cases Everyone Should Know
Episode 338 -- Deep Dive into the Deere SEC FCPA Case
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
New export controls, new section 301 duties, new OFAC requirements, new de minimis rule, new DOJ corporate compliance guidance, new international guidance on Russian sanctions. September had it all....more
We are all familiar with — over and over — third-party risks and FCPA risks. It is drilled in our collective heads — third-party risks and bribery. Legal and compliance professionals have to learn and understand the ins...more
As the interplay between export controls, trade sanctions, and anticorruption enforcement continues to intensify, multinational companies must remain vigilant in ensuring that their compliance programs address the many...more
The Justice Department has repeated on several occasions that it intends to aggressively prosecute corporations for sanctions and export controls violations. The “New FCPA” is how the Justice Department characterizes its...more
In this new era of aggressive sanctions enforcement, companies have to understand the red lines that define where criminal and civil enforcement risk increase. In contrast to the history of FCPA enforcement, DOJ and OFAC...more
With the beginning of the “New FCPA” era coined by DOJ’s Deputy Attorney General Lisa Monaco, we now need to focus on third-party risk and sanctions enforcement. The law, the practice, and the risks are important and not just...more
Sorry to start a four-part series with a reference to music from our long-ago past. The Four Tops sang the “Same Old Song, with a Different Meaning” (released in 1965). So, how does that relate to third-party risks? Well,...more
President Biden recently signed a foreign aid bill that will have significant implications for United States sanctions enforcement, specifically Section 206 of the International Emergency Economic Powers Act (50 U.S.C. 1705)...more
International Compliance Digest is the new Adams and Reese monthly newsletter focused on international trade compliance and enforcement. Each month we will bring you the latest in compliance and enforcement updates, including...more
As lawyers, corporate executives and federal law enforcement officials prepare to gather this week in San Francisco for the ABA’s 39th National Institute on White Collar Crime, we offer our takeaways from January’s Houston...more
If companies operated with perfect governance mechanisms and controls, they would all be ready for the coming sanctions enforcement storm. However, that is not the corporate reality. Even after several companies are the...more
There are some things you learn best in calm, and some in storm. Willa Cather I know I sound like a broken record. The Justice Department’s white collar criminal enforcement has been trending down over the last few...more
2023 was a banner year in the sanctions space and regulators seem primed to continue that performance in 2024. In December 2023, numerous government officials and industry experts convened at the New York Forum on Economic...more
A veritable grab bag of international trade developments to parse this week. Recent developments include increasing FCPA enforcement, a record OFAC economic sanctions penalty, and a large customs penalty for willful failure...more
The past few weeks have not been kind to 3M. The company recently settled with the SEC for $6.5 million to resolve alleged FCPA violations related to its Chinese subsidiary’s dealings with Chinese state-owned healthcare...more
Let’s move beyond the headline – trade compliance is the new FCPA. We get it. The next step is to do something about it. The Justice Department has repeated this refrain – it is one of its greatest hits. In addition, DOJ,...more
DOJ Increases Resources To Investigate and Prosecute Sanctions Evasion and Export Control Violations - On March 2, 2023, during a keynote speech at the American Bar Association’s annual White Collar Crime National...more
Deputy Attorney General (DAG) Lisa Monaco once again delivered groundbreaking remarks at the American Bar Association (ABA) National Institute on White Collar Crime (ABA White Collar Conference) on March 2, 2023, this time...more
Last week, Deputy Attorney General Lisa Monaco’s statements to the American Bar Association again highlighted the fact that investigating and prosecuting individuals for violating economic sanctions, export controls, and...more
As the Russia – Ukraine war rages on, one outcome so far is clear: the Western nations remain aligned and united to confront Russian aggression. The West’s synchronized, roll-out of economic and trade sanctions against...more
Are you a US-headquartered company with international business operations? How confident are you that your company and its agents, employees, affiliates, or subsidiaries are not dealing with foreign countries, geographic...more
In line with the Biden administration’s declaration last year that anticorruption is a “core United States national security interest,” sanctions evasion enforcement rapidly has become a core priority for the Department of...more
ACI is excited to welcome you back in-person to the 14th Advanced Forum on FCPA & Anti-Corruption for the Life Sciences Industry, taking place on July 21–22, 2022 in Boston! Legal and compliance professionals from...more
Hold onto your hats – while we are on the cusp of more FCPA enforcement actions, the Justice Department and OFAC are gearing up for real and significant sanctions enforcement actions. The dye is cast, so here we go. ...more