FCPA Compliance Report: Recent DOJ Policy Announcements
Daily Compliance News for June 11, 2025. The A Bondi Too Far Edition
Upping Your Game: Continuous Monitoring with AI
Compliance into the Weeds: Changes in FCPA Enforcement
FCPA Compliance Report: The Role of Culture and Data in Fraud Risk Management - A Conversation with Vincent Walden
Compliance in the Former Soviet Central Asian Republics
Innovation in Compliance: Staying the Course in Compliance: Insights from Kristy Grant-Hart
FCPA Compliance Report: The Power of Peer Support and Purpose Driven Leadership with Sarah Cole
Daily Compliance News: May 19, 2025, The Definition of Corruption Edition
FCPA Compliance Report: Upping Your Game in Compliance
Everything Compliance: Episode 153, The CW 25 Edition
FCPA Compliance Report: Ethical Decision - Making in Times of Change
Great Women in Compliance: Exploring the Future of Compliance - Key Takeaways from Compliance Week 2025
Upping Your Game: Episode 1 – Meeting Hui Chen’s Challenge
FCPA Compliance Report: From Compliance to Commercial Value: Removing Friction with AI
Daily Compliance News: April 28, 2025, The Santos Sobs Edition
FCPA Compliance Report: Ellen Hunt on Compliance ROI and on a Due Diligence and the US Sentencing Guidelines
FCPA Compliance Report: Amanda Carty on a Due Diligence and Risk Management
FCPA Compliance Report: Kristy Grant-Hart on A 360° Review of the Future of Compliance
Episode 365 -- Four Sanctions Cases Everyone Should Know
DOJ issues updated guidelines, ending temporary “pause” on FCPA enforcement and focusing potential enforcement on priority areas. On June 9, 2025, Deputy Attorney General Todd Blanche issued a memorandum (the Guidelines)...more
On February 10, 2025, President Donald J. Trump signed Executive Order 14209, titled “Pausing Foreign Corrupt Practices Act Enforcement to Further American Economic and National Security.” That order marked a major shift in...more
On June 9, 2025, the Deputy Attorney General of the United States Department of Justice issued “Guidelines for Investigations and Enforcement of the Foreign Corrupt Practices Act (FCPA)” (the “Memorandum”). The Memorandum...more
On December 5, 2024, DOJ announced a settlement with McKinsey and Company for $122 million for bribes paid to South African government officials to secure valuable consulting contracts....more
The Justice Department is encouraging companies to voluntarily disclose criminal violations — “Come in and confess” and DOJ offers promises of a declination. But even a declination comes with a requirement — the company has...more
While FCPA enforcement against companies has been relatively quiet this year, despite a strong beginning to the year — the SAP case for $220 million; and the Gunvor case for $661 million — DOJ has been pushing a number of...more
Last month, I wrote a blog post on the tone at the top, exemplified in Star Trek’s Original Series episode, Devil in the Dark. Based on the response, some passionate Star Trek fans are out there. I decided to write a series...more
I recently spoke with the Foreign Corrupt Practices Act (FCPA) Handbook authors Robert Tarun and Peter Tomczak from Baker McKenzie for a two-part podcast episode. The depth of knowledge and experience in white-collar crime,...more
On the heels of the Gunvor FCPA settlement for $661 million, DOJ announced its settlement with Trafigura, the latest commodities trading company to fall under DOJ's FCPA Sweep against the industry. Trafigura joined the list...more
We continue our exploration of the resolution of the FCPA enforcement action involving the Swiss trading firm Gunvor S.A. The enforcement action came in with a $661 million penalty against the company, which has pleaded...more
Over the past 15 months the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) has made clear through three Foreign Corrupt Practices Act (FCPA) enforcement actions and speeches, their priorities in...more
Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, our Foreign Corrupt Practices Act (FCPA) Year In Review provides quick, visual representations of key trends in FCPA enforcement over...more
The Department of Justice’s (DOJ) conduct since announcing its February 22, 2023, Voluntary Self Disclosure (VSD) policy, demonstrates that the government continues to place a premium on corporate cooperation in both criminal...more
Summary - The Department of Justice (DOJ) has created the International Corporate Anti-Bribery initiative (ICAB), which aims to strengthen the United States’ global efforts in combating corruption through enhanced...more
As everyone knows, I tend to repeat myself — DOJ does as well. Over the past year, DOJ has warned global companies — over and over — about the coming criminal enforcement storm against companies for sanctions and export...more
On August 10, 2023, the U.S. Securities Exchange Commission (“SEC”) and the Department of Justice (“DOJ”), in coordination with Columbian authorities, announced that Colombian conglomerate Grupo Aval Acciones y Valores S.A...more
In June, two prominent Ohioans were sentenced for their involvement in one of the largest political scandals in Ohio’s history. Former Speaker of the Ohio House of Representatives Larry Householder and former Chair of the...more
Ericsson, a multinational telecommunications company, based in Sweden, settled its breach of its 2019 Deferred Prosecution Agreement, agreed to enter a guilty plea and pay a $206 million penalty. In 2019, Ericsson entered...more
Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption law and enforcement developments from the past...more
The Justice Department and the Securities and Exchange Commission bounced back in 2022 to restore their records for aggressive FCPA enforcement. At the same time, DOJ announced significant new compliance program...more
Venice is one of the most unique and beautiful cities on earth. It was a great maritime power for over 1000 years. At the height of its power, it was the richest city on earth, worth almost 10 times more than the entire...more
Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption law and case developments from the past month,...more
At a September 15, 2022, speech at New York University School of Law, US Deputy Attorney General (Deputy AG) Lisa Monaco announced several new policies intended to further the aggressive stance the US Department of Justice...more
Deputy Attorney General (DAG) Lisa Monaco announced several significant policy updates affecting the U.S. Department of Justice’s (DOJ) enforcement practices for both corporations and individuals on September 15, 2022...more
The Justice Department has been promising a new, more aggressive approach to FCPA enforcement. DOJ officials have made statements to that effect on numerous occasions. The Biden Administration touted its elevation of the...more