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Foreign Corrupt Practices Act (FCPA) Corruption Internal Investigations

Thomas Fox - Compliance Evangelist

What is a Root Cause Analysis?

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

The Volkov Law Group

Lessons Learned from Ericsson’s DPA Breach: An Internal Investigation Nightmare (Part III of III)

The Volkov Law Group on

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

Society of Corporate Compliance and Ethics...

[Event] Basic Compliance & Ethics Academy - May 8th - 11th, Chicago, IL

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

Society of Corporate Compliance and Ethics...

[Event] Basic Compliance & Ethics Academy - February 27th - March 2nd, Scottsdale, AZ

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

Society of Corporate Compliance and Ethics...

[Event] Basic Compliance & Ethics Academy - January 23rd - 26th, Lake Buena Vista, FL

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

Society of Corporate Compliance and Ethics...

[Event] Basic Compliance & Ethics Academy - August 22nd - 25th, Las Vegas, NV

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

Society of Corporate Compliance and Ethics...

[Event] Basic Compliance & Ethics Academy - May 16th - 19th, Boston, MA

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

Society of Corporate Compliance and Ethics...

[Event] Basic Compliance & Ethics Academy - April 11th - 14th, Washington, DC

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

Society of Corporate Compliance and Ethics...

[Event] Basic Compliance & Ethics Academy - March 7th - 10th, San Diego, CA

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

Thomas Fox - Compliance Evangelist

Fraud Eats Strategy - Navigating the Steps of an FCPA Investigation – Part 2

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

Society of Corporate Compliance and Ethics...

[Event] Basic Compliance & Ethics Academy - August 9th - 12th, New Orleans, LA

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

Thomas Fox - Compliance Evangelist

Introduction to Internal Reporting and Investigations on 31 Days to a More Effective Compliance Program

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

Thomas Fox - Compliance Evangelist

The Astros Cheating Scandal and Compliance – Part 5: The Whistleblower and The Amnesty

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

The Volkov Law Group

Quad/Graphics Settles SEC FCPA Case for Nearly $10 Million

The Volkov Law Group on

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

Ballard Spahr LLP

The EU’s Efforts to Combat Money Laundering, the Financing of Terrorism and Corruption Seem to Overlook a Very American Approach:...

Ballard Spahr LLP on

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 Volkov Law Group

A Classic Criminal Investigation: Unraveling PDVSA Corruption

The Volkov Law Group on

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

Thomas Fox - Compliance Evangelist

Walmart FCPA Enforcement Action: Part 1 – Introduction

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

The Volkov Law Group

Fresenius Pays $231 Million to Resolve Long-Standing FCPA Enforcement Action (Part I of III)

The Volkov Law Group on

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

Thomas Fox - Compliance Evangelist

Flame On-Tribute to the Fantastic Four: Part II – Four Issues from the FCPA Corporate Enforcement Policy

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

Holland & Knight LLP

Petrobras Agrees to Pay More Than $1.8 Billion for Facilitating FCPA Violations

Holland & Knight LLP on

• 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

Thomas Fox - Compliance Evangelist

The NPA; The Petrobras FCPA Enforcement Action: Part III

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

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - August 2018

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

Jones Day

Corporate Anticorruption Compliance Programs: Ten Questions Every Board Director Should Ask

Jones Day on

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

Thomas Fox - Compliance Evangelist

Day 8 of One Month to Better Investigations and Reporting Day 8-Preparing for the Investigation

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

Thomas Fox - Compliance Evangelist

Day 3 of One Month to Better Investigations and Reporting-the Investigation Protocol

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

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